Supplier Code of Conduct

Last reviewed: July 2026.

Every TURTLEGROOVE garment is cut and sewn 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 — including the places where we cannot yet verify 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. TURTLEGROOVE is a certified Fur Free Retailer; suppliers must be able to confirm in writing that nothing they supply to us contains animal-derived content.
• No subcontracting. Every stage of TURTLEGROOVE garment manufacturing takes place in our partners' own facilities. Subcontracting is not permitted. A partner may not pass any part of our work — cutting, sewing, washing, finishing or anything else — to a third party without our prior written approval, and undisclosed subcontracting is grounds for ending the relationship.
• Disclosure. Partners must tell us where our garments and our fabric are actually made, and provide current certificates on request. We publish what we are told, and we publish where we have not been told.

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 the facilities that knit, dye and wash our fabric — 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.
• PFCs / PFAS — per- and polyfluorinated “performance” finishes of any kind (water-repellent, stain-resistant or otherwise).
• 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. Our fabric is knitted, dyed and washed under GOTS Scope Certificate CU848243GOTS-2026-00010952. GOTS 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. Our embroidery thread is 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. We publish the full street address of every facility, and we publish plainly what is certified and what is not.

As of July 2026, Jerico is our sole garment manufacturer — every piece we make, sweatshirts and t-shirts alike, comes from this one fully disclosed, GOTS-certified fabric supply chain.

Stage	Facility & address	Certification
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.	Organic, under a GOTS-recognised farming standard. We know the country and the standard, but not the individual farms — and we do not claim farm-level traceability.
Fabric knitting	Fine Cotton Factory Inc. 110 Belfield Road Etobicoke, Ontario, Canada (also a primary investor in Jerico)	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. ✅ Verified — we hold the certificate.
Dyeing, washing and finishing	Canadian Textiles Services 189 Summerlea Road Brampton, Ontario, Canada	Named and audited as a certified facility on the same GOTS certificate. ✅ Verified.
Cutting and sewing	Jerico 120 Commander Blvd Toronto (Scarborough), Ontario, M1S 3H7, Canada	Canadian labour law. Jerico holds no textile certification of its own, and we do not claim otherwise.
Embroidery, finishing, packing	TURTLEGROOVE Burlington, Ontario, Canada (our own facility)	Operated by us, under Canadian labour law.

A note on OCS and GOTS — they are not the same thing

It matters which certification a brand is talking about, and most brands never explain the difference. GOTS (Global Organic Textile Standard) verifies organic content and restricts hazardous chemicals and dyes, and requires wastewater from wet processing to be treated, and carries ILO-based social criteria that are audited on site. OCS (Organic Content Standard) verifies organic content and chain of custody — and nothing else. It says nothing about dyes, effluent or labour conditions.

So when we say our fabric is GOTS-certified, we mean the chemistry and the wastewater and the labour standards were audited — not simply that the cotton is organic. Those are different claims, and we will not blur them.

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.

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 garment 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 requires 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, domestic and now single-source, 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 partner is not itself GOTS-certified. We have not traced our cotton to individual farms. We do not publish worker-level data such as headcount, gender breakdown or migrant-worker proportions. We would rather list all of that 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, undisclosed subcontracting, refusal to disclose where our fabric is made, 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. Consolidating all of our production with Jerico in July 2026 was, in part, an application of this principle: we could not obtain the fabric disclosure we require from our previous second manufacturer, so we ended that relationship and moved the entire range.

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 fabric certificate expires on 27 January 2027 and will be renewed and republished.

Related: Our sustainability commitments · Made in Canada · Our impact