Code of Conduct Suppliers

Code of Conduct

1. Introduction 2. Human rights and labour rights 3. Environment 4. Animal welfare 5. Anti-corruption 6. Implementation and process 7. Contact information

1. I N T R O D U C T I O N Eton’s business concept is to offer high quality shirts and accessories. Quality also means that our products must be manufactured in a way that is sustainable. We are therefore committed to working very closely with our suppliers and business partners to achieve sustainable social and environmental standards in the factories that manufacture Eton’s products and in the operations of other business partners.

1.1 Scope This Code of Conduct is applicable to all suppliers, subcontractors and business partners that do business with Eton AB. This Code of Conduct specifies what we require from our suppliers and other business partners in order to fulfil our commitment to our stakeholders, including our customers, retailers and other business partners, employees, owners, and the communities where we operate. These requirements are applicable to all processes and stages of the value chain and it is the responsibility of Eton’s suppliers to inform their subcontractors about Eton’s Code of Conduct and to ensure that these are being implemented in production, procurement and distribution processes carried out on behalf of Eton. This document should be seen as a minimum and not a maximum standard – Eton encourages companies to exceed these standards.

1.2 Basis for the code We have aligned our Code of Conduct with the UN Global Compact and its applicable international agreements: the UN Universal Declaration of Human Rights1, the International Labour Organization Conventions 2, the UN Convention against Corruption 3 and the Rio Declaration on Environment and Development 4.

1.3 Laws and regulations Eton’s rule is that all our suppliers and other business partners must, in all their activities, follow the national laws and regulations in the countries in which they operate as well as Eton’s company policies and agreements. Should any requirement in this code conflict with the national law in any country or territory, the supplier shall follow the highest applicable standard and inform Eton of the conflict.

1. http://www.un.org/en/universal-declaration-human-rights/ 2. http://ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang--en/index.htm 3. https://www.unodc.org/unodc/en/corruption/tools_and_publications/UN-convention-against-corruption.html 4. http://www.un.org/documents/ga/conf151/aconf15126-1annex1.htm

2. HUMAN RIGHTS AND LABOUR RIGHTS 2.1 Child labour Eton does not accept the use of children or minors under the minimum legal working age or fifteen (15) years old, whichever is higher, as labour. Employees under the age of 18 shall not carry out hazardous work, heavy work or work night shifts.

2.2 Employment is freely chosen We do not accept any forms of forced or bonded labour and we do not accept the use of prison labour or illegal labour in the production of goods or services for Eton AB. Migrant workers are particularly exposed and shall be protected. The employer shall not demand any compulsory deposits of money or identity papers and recruitment fees required by agents are strictly prohibited. Employees shall be free to leave their workplace after working hours and quit their employment after giving reasonable notice, as agreed upon in the employment contract described in chapter 2.6 of this Code of Conduct.

2.3 Freedom of association and the right to collective bargaining All employees have the right to form or join associations of their own choosing, and to bargain collectively. Eton AB does not accept any prejudicial acts from the employer against employees, including dismissal, who choose to join or represent an association.

If the right to collective bargaining and freedom of association is restricted by law, the employer shall facilitate the development of independent and free workers’ representation and negotiations.

2.4 Every employee shall be treated with respect and dignity Under no circumstances do we accept the use by our suppliers, subcontractors or other business partners of humiliating or corporal punishment, and no employee shall be subject to physical, sexual, psychological or verbal harassment or abuse.

2.5 No discrimination Discrimination is not tolerated. Discrimination based on gender, race, age, pregnancy, sexual orientation, religion, caste, political opinion, nationality, ethnic origin, social background, disease or disability or any other condition that could give rise to discrimination, shall not occur at any occasion, such as hiring, compensation, training, promotion, termination and retirement.

2.6 Employees are entitled to written employment contracts All employees are entitled to a written employment contract, in a language understandable to them, which at least contains: working hours, overtime compensation, notice period, salary and frequency of payment. Workers in apprentice programmes shall be provided with the same rights as regular employees. The employer has a responsibility to ensure that all employees are aware of their legal rights and obligations.

2.7 Wages Suppliers shall ensure that all employees are given a living wage, relevant to the specific geographic area where business is conducted. The wage must at least be enough to cover basic needs for the employee and its family and provide some discretionary income. The salary progression of an employee must reflect his or her experience, qualifications and performance.

All other types of legally mandated benefits and compensations shall be paid. Wages must be paid directly to the employee, at least once a month. No unfair deductions are allowed, and the employee has the right to a written specification of how the wage has been calculated. The factory should have a system or documentation to verify working time (regular, overtime and compensation).

2.8 Working hours are not excessive Ordinary working hours must not exceed 48 hours per week. Overtime work shall not exceed 12 hours per week. Overtime work must always be voluntary and compensated at a premium rate.

Employees are entitled to appropriate resting breaks and lunch break during working hours, and to at least one day off in every seven-day period. Employees shall be entitled to sick leave, maternity leave and annual leave.

2.9 Health and safety The safety of employees is a priority at all times and adequate steps shall be taken to prevent accidents and injury to health before they happen. No unsafe buildings or hazardous equipment are accepted and the working conditions shall at all time be safe and hygienic. First aid equipment must be easily accessible to employees at all times.

Appropriate training must be provided for equipment and the employer shall always provide effective Personal Protective Equipment (PPE) to all workers free of charge.

2.10 Fire safety Emergency exits must be clearly marked and unblocked all the way out of the building. Evacuation through emergency exits must always be possible during working hours. Evacuation plans and firefighting equipment must be provided in a language understandable to all employees.

2.11 Working conditions The employer shall ensure access to drinking water, clean and gender separated toilet facilities, safe and clean eating and resting areas as well as food storage areas. Accommodation, if provided, shall be clean, safe, and meet the basic needs of the employees including adequate ventilation.

2.12 Trainings The employer shall assign responsibility for health and safety to a senior management representative. Employees shall be given regular and recorded health and safety training, and such training shall be repeated for new or reassigned employees. All employees must be trained in how to act in case of fire, and annual evacuation drills are required.

3.ENVIRONMENT 3.1 General environmental requirements Eton strives to minimize the environmental impact of our operations. Suppliers shall promote the development and use of environmentally friendly production methods and conduct business with as little impact on the environment and public health as possible.

3.2 Reduction targets The supplier shall have an environmental policy and program in place with measurable targets and objectives, including a risk assessment to prevent, mitigate and control the impact of their operations.

3.3 Emissions and waste Suppliers shall strive to minimize greenhouse gas emissions by identifying, managing, monitoring, and controlling air emissions from their operations. The supplier should also prioritize transportation with the least environmental impact. Supplier shall monitor, control, and treat wastewater and solid waste generated from operations, industrial processes, and sanitation facilities before discharge or disposal.

3.4 Energy and water Suppliers shall use energy and water responsibly and strive towards reducing their consumption by setting reduction targets and monitoring energy and water use regularly. Renewable energy sources shall be prioritized and water shall be treated and reused when possible.

3.5 Chemicals Chemicals shall be handled in accordance with Eton’s Chemical Restriction List and all chemical containers must be properly labelled and safely stored.

4. ANIMAL WELFARE The Five Freedoms of animal welfare, as adopted by the Farm Animal Welfare Council, are essential, and as a minimum animals shall be entitled: • Freedom from hunger or thirst • Freedom from discomfort • Freedom from pain, injury or disease • Freedom to express normal behaviour • Freedom from fear and distress

5. ANTI-CORRUPTION Suppliers shall uphold the highest ethical standards when doing business. Corruption in all its forms including, but not limited to bribery, facilitation payments and nepotism is strictly prohibited. Suppliers shall be committed to preventing, detecting and remedying financial crime, including but not limited to extortion, money laundering and fraud.

It is never allowed for suppliers directly or indirectly to demand, offer, ask for, give or accept a gift or undue advantage in exchange of a personal advantage from any party.

Business decisions shall not be motivated or influenced by personal relationships or interests.

The supplier shall not enter into a financial or any other relationship with a party that creates or gives the appearance of a conflict of interest.

6.IMPLEMENTATION AND PROCESS Eton expects all its suppliers and other business partners to respect this Code of Conduct and to actively do their utmost to achieve our standards. We require our suppliers and other business partners to be ethical, transparent and not intentionally mislead us, or our auditors. We believe in cooperation and we are willing to work with our suppliers and other business partners to achieve sustainable solutions and to promote suppliers and other business partners who are in compliance.

Relevant documentation must be maintained for auditing purposes. We reserve the right to make unannounced visits to all units producing goods or services, including sub-contractors, for Eton AB at any time. We also reserve the right to appoint an independent third party of our choice to conduct audits in order to evaluate compliance with our Code of Conduct. During audits we require unrestricted access to all areas of the premises, to all documents and to all employees for interviews.

Eton’s audits aim to identify gaps between the requirements in this Code of Conduct and the actual practices and conditions in the workplace. The audited company will always be given the opportunity to propose and implement a corrective action plan. Eton will follow up the implementation of the plan and verify that violations have been remedied. It is the expectation of Eton that the supplier and its sub-suppliers comply with this Code of Conduct and any corrective action plans or follow-up audits will therefore not be at the expense of Eton. A supplier failing to undertake sustainable improvements within the stipulated time frame would seriously damage its relationship with Eton. Eton’s mission is to cooperate with suppliers to address the underlying causes to the non-compliance and to implement continuous improvements. Terminating business with existing suppliers will take place in the events of repeated failure or unwillingness to carry out corrective actions.

In order to ensure that this Code of Conduct is clearly communicated to all employees and subcontractors, we want suppliers to inform all staff about its existence and to offer an updated version translated into the local language to all employees. This Code of Conduct is only valid in the English language and any translations shall only be considered as helpful tools. If this document is found in different language versions, these shall be considered of convenience only and the English version shall overrule in any case of inconsistency.

7. C O N T A C T I N F O R M A T I O N Suppliers and their employees that have questions about the Code of Conduct, or who wish to give feedback to Eton’s management, are welcome to send an email to: csr@etonshirts.com. Any breach or suspected breach towards the principles in this Code of Conduct shall be emailed to Eton and this will not be used against the employee if acting in good faith. All feedback will be handled anonymously.

ETON CODE OF CONDUCT COMPLIANCE COMMITMENT We hereby confirm that we have read and understood Eton’s Code of Conduct. We commit to comply with the Code of Conduct. It is our responsibility to inform all of our employees and subcontractors about the content in the Code of Conduct and to secure their compliance.

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