Factory Code of Conduct

When customers buy our goods they must be sure that they have been produced under acceptable conditions. That means the goods must have been produced:

• Lawfully, through fair and honest dealing;
• Without exploiting the people who made them;
• In decent working conditions; and
• Without damaging the environment.

This code applies to the supplier, manufacturer or any other person involved in supplying goods to our companies. We have asked you to follow this code. The code is backed up by a process of self-evaluation and independent inspections to make sure you keep to it. The code is designed to be fair, achievable, and easy to check, and to promote the ongoing development of our suppliers. It is based on International Labour Organisation (ILO) conventions and recommendations. The goods must be made at the factory named in the purchase order.

Legal requirements - At all times, you must meet the legal requirements of the countries in which you are working. The employer must only employ workers who are legally entitled to enter into employment in accordance with national immigration law.

Manufacturing processes – You are reminded that all premises involved in manufacture are subject to these standards. Sub-contracted processes – which are processes being carried out by another factory unit, or from domestic premises (home-working) – must be declared when
the order is placed, and have our written permission.

Animal products programme
We are committed to making sure our products are from fair and ethical sources.
All suppliers must be socially responsible when using animal products.
For this reason we have introduced a ‘Declaration of Ethical Compliance for Animal Products’.
This means that you must meet the following conditions.

• You must only use leathers, skins and feathers that are by-products of the slaughter of an animal. Global standards agreed by the OIE (World Organisation for Animal Health) are set out in their practices for the protection of animals at the time of slaughter.

• You must not use products from endangered species on the CITES (Convention on International Trade in Endangered Species) or IUCN (International Union for the Conservation of Nature) list.

• You must not use real fur (except for sheepskin, goatskin and cowhide) or pelts on any goods supplied to us.

• You must not use karakul (also known as broadtail and astrakhan), or any skin products from aborted animals in goods supplied to us.

• You must not use any leather that was taken while the animal was alive. Stunning and slaughter guidelines are laid out for different species in the OIE global standards.

• No feathers should be plucked from live animals. Feathers must only be purchased from licensed organisations with certification.

• No cosmetics sold by the Noblecontrol Group should be tested on animals.

You must keep to these conditions for the programme to work. This is a long-term programme that aims to make sure:

• Animals are treated in a humane and ethical way; and

• You and we keep to any relevant laws, such as those on hygiene and waste disposal.

Noblecontrol Code of Conduct (January 2007)

a Employment is freely chosen

1 There is no forced, bonded or involuntary prison labour.

2 Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice.

b Freedom of association and the right to collective bargaining are respected

1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.

3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.

4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

c Working conditions are safe and hygienic

1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

d Child labour shall not be used

1 Child labour shall not be used.

2 There shall be no new recruitment of child labour.

3 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; "child" and "child labour" being defined later in this section.

4 Children and young persons under 18 shall not be employed at night or in hazardous conditions.

5 These policies and procedures shall conform to the provisions of the relevant ILO (International Labour Organisation) standards.

e Living wages are paid

1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

f Working hours are not excessive

1 Working hours comply with national laws and benchmark industry standards, whichever affords greater protection.

2 In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and
shall always be compensated at a premium rate.

g No discrimination is practised

1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

h Regular employment is provided

1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.

2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, or home- working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

I No harsh or inhumane treatment is allowed

1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

The provisions of this code constitute minimum and not maximum standards, and this code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this Base Code address the same subject, to apply that provision which affords the greater protection.

Definitions

Child

Any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply. If however, local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention No. 138, the lower will apply.

Young person

Any worker over the age of a child as defined above and under the age of 18.

Child labour

Any work by a child or young person younger than the age(s) specified in the above definitions, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the child's or young person's education, or to be harmful to the child's or young person's health or physical, mental, spiritual, moral or social development.

Our Code should be displayed to factory workers in their own language. Translated copies are available on the ETI website: http://www.ethicaltrade.org/resources/key-eti- resources/eti-base- code.

If any workers are illiterate, the Code should be communicated to them verbally.