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Code of Conduct for Schurman Retail Group Suppliers

  1. 1. Normative Elements
    • 1.1. Supplier shall comply with the national (or national and local) labor law in additional to this procedure.
    • 1.2. When the national or local labor law and this procedure address the same issue, that provision which is most stringent applies.
  2. 2. Requirements
    • 2.1. Child Labor
      • 2.1.1. Supplier shall not employ workers under 15 years old or younger than the age for completing compulsory education or younger than the minimum age for employment in the country of manufacture where such age is higher than 15.
      • 2.1.2. Supplier shall follow any restrictions for employment of young workers over 15 years. Workers under the age of 18 shall not perform work that is likely to jeopardize their health or safety, including night shifts or overtime.
    • 2.2. Forced Labor
      • 2.2.1. Supplier shall not employ forced labor, bonded labor, indentured labor or prison labor.
      • 2.2.2. Supplier shall not hold monetary deposits or hold, conceal, confiscate, destroy or otherwise deny access to worker passports, work permits or identity cards of workers upon commencing employment or any time thereafter.
      • 2.2.3. Supplier shall not transport, harbor, recruit, transfer or receive persons by means of threat, force, coercion, abduction or fraud for labor or services.
      • 2.2.4. Supplier shall not impose any unreasonable restriction on its workers' freedom of movement in the subject facilities or on entering or exiting company provided facilities.
      • 2.2.5. For foreign workers, as part of the hiring process, workers must be provided with a written employment agreement in their primary language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin.
      • 2.2.6. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment.
      • 2.2.7. Workers shall not be required to pay employers' or agents' recruitment fees or other related fees for their employment.
      • 2.2.8. Supplier shall use reasonable efforts to responsibly source ingredients, materials and components which Supplier integrates into finished products that are supplied to Schurman Retail Group. Such efforts shall include Supplier taking reasonable efforts to ensure that its suppliers substantially comply with labor guidelines in conformity with this Code of Conduct, generally, and does not involve human trafficking or slavery specifically.
    • 2.3. Working Hours
      • 2.3.1. Supplier shall comply with the local government’s labor laws regarding the working hours and overtime policy.
      • 2.3.2. The normal work week, including overtime, shall not on a regular basis exceed 60 hours. Workers shall be provided with one day off in every seven day period.
    • 2.4. Wages & Compensation
      • 2.4.1. Supplier shall comply with the local labor laws, rules and regulations regarding the minimum wage policy.
      • 2.4.2. Overtime work must be paid at a premium rate per local labor laws, rules and regulations.
      • 2.4.3. Supplier shall not deduct from wages for disciplinary purposes.
      • 2.4.4. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation which is understandable and contains sufficient information to verify accurate compensation for work performed.
    • 2.5. Health and Safety
      • 2.5.1. Supplier shall provide a safe and healthy workplace and shall take adequate steps to prevent accidents and injury.
      • 2.5.2. Supplier shall provide emergency medical services to the workers.
      • 2.5.3. Supplier shall provide to workers adequate safety and personal protection equipment and training in their primary language.
      • 2.5.4. Supplier shall provide, for use by all workers, clean washrooms and access to potable water and sanitary facilities.
      • 2.5.5. Supplier shall ensure dormitory facilities are clean, safe and meet the basic needs of the workers.
      • 2.5.6. Supplier must implement emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
      • 2.5.7. Supplier shall have in place procedures and systems in place to manage, track, prevent and report occupational injury and illness.
      • 2.5.8. Supplier shall have in place procedures, practices and policies to identify evaluate and control worker exposure to chemical, biological and physical agents.
      • 2.5.9. Supplier shall have in place procedures, practices and policies to identify, evaluate, and control worker exposure to the hazards of physically demanding tasks.
      • 2.5.10. Supplier shall have in place procedures, practices and policies to identify evaluate and control worker safety risks arising from production and other machinery.
    • 2.6. Freedom of Association
      • 2.6.1. Supplier shall respect the right of workers to form and join unions of their choice, to bargain collectively, to associate freely, seek representation, and join workers’ councils.
      • 2.6.2. Supplier shall ensure that the representatives of trade unions are not the subject of discrimination.
    • 2.7. Discrimination
      • 2.7.1. Supplier shall not engage in discrimination in hiring, remuneration, training, promotion, rewards, retirement or termination based on race, color, religion, disability, gender, sexual orientation, union membership ethnicity, pregnancy, political affiliation, marital status or age.
      • 2.7.2. Supplier shall not allow behavior including gestures, language and physical contact, that is sexually harassing or abusive.
      • 2.7.3. Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
    • 2.8. Disciplinary Practices
      • 2.8.1. Supplier shall not punish workers physically or mentally.
      • 2.8.2. Supplier’s disciplinary policies and procedures shall be clearly defined and communicated to workers in their primary language.
      • 2.8.3. Workers shall be able to communicate openly with management regarding working conditions and safety without fear of reprisal, intimidation or harassment.
    • 2.9. Environmental Protection
      • 2.9.1. Work place must meet local environmental protection laws, rules and regulations and, where required, be approved by the appropriate local agency.
      • 2.9.2. Supplier shall obtain, maintain and keep current all required environmental permits, approvals and registrations.
      • 2.9.3. Supplier shall reduce and eliminate the use of resources and generation of waste of all types, including water and energy, at the source or by practices such as modifying production, maintenance, and facility processes, materials substitution, conservation, recycling and re-using materials.
      • 2.9.4. Supplier shall identify and manage chemicals and other materials posing a hazard if released to the environment to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
      • 2.9.5. Supplier shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).
      • 2.9.6. Supplier shall conduct routine monitoring of the performance of its air emission control systems to minimize the discharge of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations.
      • 2.9.7. Supplier shall implement a systematic approach to prevent contamination of storm water runoff.
      • 2.9.8. Supplier shall track and document energy consumption and greenhouse gas emissions. Supplier shall look for cost effective methods to improve energy efficiency and to minimize its energy consumption and greenhouse gas emissions.
    • 2.10. Subcontracting
      • 2.10.1. Subcontractors are allowed, upon notification to Schurman Retail Group, and supplier is responsible to ensure the subcontractor’s compliance.
      • 2.10.2. Subcontracting to home workers is not allowed.
    • 2.11. Record Keeping
      • 2.11.1. Supplier shall maintain appropriate records to demonstrate its conformity with the requirements of this procedure.
  3. 3. Access for Verification
    • 3.1. Supplier shall, in a timely manner, provide reasonable information, documents, records, materials and make employees and facilities available to Schurman Retail Group to verify its conformity with the requirements of this procedure.
  4. 4. Supplier Agreement
    • 4.1. Supplier shall sign the code of conduct agreement to accept and agree to abide by the code.
  5. 5. Factory Audits
    • 5.1. All Suppliers must complete and sign the Pre Audit Questionnaire, Code of Conduct Agreement, and provide a Certificate of Liability Insurance prior to shipments.
    • 5.2. Schurman Retail Group reserves the right to conduct unannounced audits.
    • 5.3. Schurman Retail Group reserves the right to terminate all business relationships with any Supplier who fails to comply with Schurman Retail Group Supplier Code of Conduct.

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