Supplier Code of Conduct

Last reviewed: July 2026.

Every TURTLEGROOVE garment is made in Ontario, Canada, by partners we know by name. This Code of Conduct sets out the standards we require of them, who they are, and how those standards are independently verified. We publish it so that anyone — customer, analyst or journalist — can check our claims rather than take our word for them.

1. Scope

This Code applies to every supplier, manufacturer and subcontractor involved in making TURTLEGROOVE products, at every stage: fibre and fabric, knitting, dyeing and finishing, cutting, sewing, embroidery, trims and packaging.

2. The standards we require

Our standards are based on the core conventions of the International Labour Organization (ILO). We require every partner to meet all of the following.

  • No child labour. No one under the legal minimum working age, and no one under 18 in hazardous work.
  • No forced labour. No bonded, indentured, trafficked or involuntary labour. No worker may be required to surrender identity documents or pay recruitment fees. All employment is freely chosen and workers are free to leave.
  • Freedom of association. Workers may form and join trade unions and bargain collectively without fear of reprisal.
  • Fair wages. Wages meet or exceed the legal minimum. Overtime is paid at the legal premium. Deductions as a disciplinary measure are prohibited. Workers receive clear, regular written pay information.
  • Working hours. Hours comply with the law. Overtime is voluntary and is not demanded on a routine basis.
  • Health and safety. A safe, clean workplace: proper ventilation, safe machinery and chemical handling, clear fire exits, protective equipment, and access to drinking water and sanitation.
  • No discrimination or harassment. No discrimination on the basis of race, ethnicity, national origin, religion, age, sex, sexual orientation, gender identity, disability, pregnancy, marital status, political opinion or union membership. No physical, verbal, sexual or psychological abuse, and no threats.
  • Regular employment. Work is performed on the basis of a recognised employment relationship. Labour-only contracting and sham apprenticeships must not be used to avoid obligations to workers.
  • Environment and chemicals. Partners must comply with applicable environmental law, must not use any of the substances prohibited in section 3 below, and must treat wastewater from wet processing before discharge.
  • Forests and deforestation. No wood-derived (man-made cellulosic) fibres — no viscose, rayon, modal, lyocell or bamboo viscose — and no leather. These are the two principal deforestation-linked material categories in fashion, and we exclude both outright. Paper, card and packaging inputs must come from responsibly managed, certified sources wherever we can obtain them, and we publish honestly where we cannot.
  • Animal welfare. No animal-derived materials of any kind. No animal testing. No animal-derived dyes, glues or finishes.
  • Transparency and subcontracting. Partners must tell us where our garments are actually made. Undisclosed subcontracting is not permitted.

3. Restricted substances — what must never be in our clothes

First, an honest limitation. We do not maintain our own Restricted Substances List (RSL) or Manufacturing Restricted Substances List (MRSL), and we are not a ZDHC signatory. We are a small brand, and writing a chemical list we lack the laboratory capacity to enforce would be theatre. Instead, our chemical restrictions are enforced through GOTS certification of every facility that does our wet processing — audited annually by an accredited independent certification body — and through the binding prohibitions below.

The following are prohibited outright in any TURTLEGROOVE product or at any stage of its production. No partner may use them, and no partner may permit them in their own supply chain.

  • Azo dyes that can release carcinogenic arylamines. We do not use them and do not allow them anywhere in our supply chain.
  • PFCs / PFAS — per- and polyfluorinated “performance” finishes of any kind (water-repellent, stain-resistant or otherwise). We do not use them and do not allow them anywhere in our supply chain.
  • Formaldehyde and formaldehyde-releasing finishes.
  • Chlorine bleaching.
  • Heavy-metal dyes and mordants — including chromium, lead, cadmium and mercury compounds.
  • Plastisol, PVC and phthalate-based prints. We do not print at all — every design is embroidered — so no print chemistry is used on any garment we make.
  • Animal-derived dyes, glues and finishes.

How this is enforced. 100% of our fabric is knitted, dyed and washed under GOTS Scope Certificate CU848243GOTS-2026-00010952 (see section 4). The GOTS standard independently prohibits azo dyes releasing carcinogenic arylamines, formaldehyde, chlorine bleaching and heavy-metal dyes, and requires every chemical input to meet strict toxicological and environmental criteria. Because all our wet processing runs through certified facilities, these restrictions apply to 100% of our production rather than to a subset of it. Our embroidery thread is separately certified to OEKO-TEX Standard 100, meaning it has been laboratory-tested for harmful substances.

4. Who makes our clothes

We publish our supply chain because transparency is the whole point of a code like this. Apart from the cotton itself, which cannot be grown in Canada, every stage takes place in Ontario.

Stage Partner & location Independent certification
Organic cotton fibre and yarn Grown and spun in India. Canada's climate cannot support cotton, so this is the one stage we cannot bring home. Certified organic under a standard recognised by GOTS; the fabric produced from it is covered by the GOTS Scope Certificate below.
Fabric — knitting, dyeing, finishing Fine Cotton Factory Inc.
110 Belfield Road, Etobicoke, Ontario
(Fine Cotton Factory is also a primary investor in Jerico, our cut-and-sew partner.)
GOTS Scope Certificate CU848243GOTS-2026-00010952, issued by Control Union Services (accredited by the ANSI National Accreditation Board) to GOTS version 7.0. Valid until 27 January 2027. Covers knitting, manufacturing, trading, dyeing and washing of 100% organic cotton knitted fabrics.
Dyeing and washing Canadian Textiles Services
189 Summerlea Road, Brampton, Ontario
Named and audited as a certified facility under the same GOTS certificate above.
Garment manufacturing — cutting and sewing Jerico — Scarborough, Ontario Canadian labour law. Jerico does not itself hold GOTS or GRS certification, and we do not claim otherwise.
Garment manufacturing Peros Garment Factory — Toronto, Ontario Organic Content Standard (OCS), certified by Textile Exchange.
Embroidery and finishing TURTLEGROOVE — Burlington, Ontario Operated by us, under Canadian labour law.

Our GOTS certificate can be checked independently in the public GOTS database at global-standard.org — search for 848243.

An important honesty note. A GOTS Scope Certificate certifies the fabric and the facilities that make it — not the finished garment. The certificate says so itself. We therefore do not claim that TURTLEGROOVE garments are GOTS-certified, and we do not use the GOTS logo. What we can say, and prove, is that our fabric is GOTS-certified 100% organic cotton, knitted and dyed in independently audited facilities in Ontario.

5. How these standards are verified

We are a small brand and we do not operate our own social-audit programme. We are direct about what our assurance actually rests on:

  • Canadian law. 100% of our manufacturing takes place in Ontario, Canada. Every facility is therefore covered by Canadian employment law — legally enforced minimum wages, regulated working hours, occupational health and safety standards, workers' compensation, and prohibitions on child and forced labour — with government enforcement behind it.
  • Third-party certification audits. GOTS and the Organic Content Standard both require on-site audits by an accredited, independent certification body as a condition of certification, renewed annually. Our fabric certificate names the certifying body (Control Union Services), lists every facility that was audited, and carries an expiry date. GOTS also carries social criteria drawn from the ILO conventions listed above.
  • Published certificates. We publish the certificate number, the certifying body and the expiry date, so anyone can verify them at source rather than taking our word for it.
  • Direct relationships. Our supply chain is short and domestic. We know our partners, and our own embroidery and finishing team works in Burlington, Ontario.

What we do not claim: we have not commissioned our own SMETA, WRAP or BSCI audits, we do not maintain our own RSL or MRSL, our cut-and-sew partners are not GOTS-certified, and we do not publish worker-level wage data. We would rather say so plainly than imply a level of assurance we do not have.

6. If a partner falls short

If we find that a partner is not meeting this Code, our first response is to fix the problem, not to walk away — cutting and running usually harms the workers involved. We will:

  1. Raise the issue directly with the partner and agree a written corrective action plan with a deadline.
  2. Follow up to confirm the issue has actually been resolved.
  3. End the relationship where a partner is unwilling to remedy a serious breach — in particular child labour, forced labour, a danger to workers' safety, or the use of a prohibited substance listed in section 3.

We will not work with a supplier who cannot demonstrate compliance with these standards.

7. Raising a concern

Anyone — a worker at one of our partners, a customer, or a member of the public — can raise a concern about conditions in our supply chain by emailing admin@turtlegroove.co. We will not retaliate against anyone who raises a concern in good faith, and we will treat reports confidentially wherever we can.

8. Review

We review this Code and our partners' certificates at least once a year, and we update this page when anything changes. Our current fabric certificate expires on 27 January 2027 and will be renewed and republished. If a certificate lapses or a partner changes, this page changes with it.

Related: Our sustainability commitments · Made in Canada

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