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1. lntroduction Trading Gifts Sweden AB has suppliers all over the world in order to be able to give our customers the best possible combination of quality, price and service. lt is very important for us to take responsibility for all our actions and to make sure that not only we, but also our suppliers and their subcontractors, follow the laws and rules that apply to their business. We strive to be a good employer and also a responsible member of society. Our goal is to find reliable, good-value products without compromising on the products quality and function. Our goal is also to make sure that our suppliers’ takes responsibility for safe and healthy working conditions and for the environment. In order to make our position clear to our suppliers, our own staff, as well as any other parties, we have set up a Code of Conduct. lt is a non-negotiable requirement from our side that all our suppliers and their subcontractors, without exception, should follow this code. In accordance with the lLO conventions, the United Nations’ Universal Declaration of Human Rights and the UN’s conventions on children’s rights and the elimination of all forms of discrimination against women, the code of conduct aims to attain compliance with certain social and environmental standards. The following requirements are of particular importance: 2. Legal requirements Our general rule is that all our suppliers must, in all their activities and without exception, follow all applicable national laws and regulations, industry minimum standards, lLO and UN Conventions, and any other relevant statutory requirements. 3. Working conditions Where local industry standards are higher than the legal requirements then these should apply. In same countries the legal requirements fall short of international legal standards and our suppliers should apply the following minimum criteria: 3. 1 Forced labour No form of forced labour, involuntary or uncompensated work will be accepted.


3.2 Discrimination Employers should endeavor to recruit, train, promote, retire and terminate workers on equal terms on the basis of suitability for the job. No discrimination shall be tolerated on the basis of gender, age, religion, race, caste, social background, disability, ethnic and national origin, nationality, membership in workers' organizations including unions, political affiliation, sexual orientation, or any other personal characteristics. 3.3 Right of association The right of workers to join and organize associations of their own choosing should be respected. In situations or countries in which the rights regarding freedom of association and collective bargaining are restricted by law, parallel means of independent and free organization and bargaining shall be facilitated. 3.4 Hours of work, days off and holidays Overtime hours are to be worked solely on a voluntary basis. The maximum allowable working hours in a week are 48 and the maximum allowable overtime hours in a week are 12. An employee is entitled to at least one free day (24 hours) following six consecutive days worked. Workers should have paid annual leave. 3. 5 Child labour Child labour is forbidden as defined by lLO and United Nations conventions and/or by national law. Of these various standards, the one that is the most stringent shall be followed. Any forms of exploitation of children are forbidden. Working conditions resembling slavery or harmful to children's health are forbidden. The rights of young workers must be protected. Employers shall not employ children who are less than 15 years old (or 14 years old in countries with insufficiently developed economies and educational facilities) or younger than the age for completing compulsory education if that age is higher than 15, if such employment jeopardizes educational, social or cultural development. We acknowledge that according to the UN Convention on the Rights of the Child, a person is a child until the age of 18. We therefore recommend our suppliers to make sure, that employees in the age group 15-18 years are treated accordingly. Limits for working hours and overtime for this age group should be set with special consideration to the workers' low age. If a child is found to be working for a supplier manufacturing Trading Gifts Sweden AB's products, we request that measures are taken to correct the problem without worsening the child's social situation. 2/4

3.6 Safety Employers must treat all workers with respect and dignity and provide them with a safe and healthy working environment. Factories shall comply with all applicable laws and regulations regarding working conditions. standards and procedures should be elaborated to protect workers from fire, accidents and toxic substances. Lighting, heating and ventilation systems should be adequate. Workers should have access at all times to sanitary facilities, which should be adequate and clean. Where residential facilities are provided for workers similar standards should apply. A workplace practice and conditions which violate basic human rights are forbidden. 4. Wages Wages paid for regular working hours, overtime hours and overtime differentials shall meet or exceed legal minimums and/or industry standards. Illegal or unauthorized deductions from wages shall not be made. In situations in which the legal minimum wage does not cover living expenses and provide same additional disposable income, companies shall strive to provide employees with adequate compensation to meet these needs. All workers with the same experience and qualifications should receive equal pay for equal work. 5. Environmental protection Suppliers shall be well aware and comply with all relevant laws and regulations regarding the protection and preservation of the environment. Procedures and standards for waste management, handling and disposure of chemicals and other dangerous materials, emissions and effluent treatment must meet or exceed minimum legal requirements. In particular, suppliers should carefully monitor discharges and waste that could pollute the local environment and strive to constantly improve the environmental performance in their operations. From June 1st 2007 a regulation ca lied REACH is applicable for all goods entering the EU. REACH stands for Registration, Evaluation, Authorization and Restriction of Chemicals. The regulation stipulates the responsibility to handle chemicals in a safe way. Chemicals that are used in the production of Trading Gifts Sweden AB products must as a minimum fulfil the actual chemical regulation of EU or the country of orig in, depending of which is the strictest. Trading Gifts Sweden AB suppliers are responsible to be aware of these regulations and follow them. Trading Gifts Sweden AB's goal is not to import any goods that contain SVHC substances (Substances of Very High Concern).


6. Application Employees responsible for purchasing products at Trading Gifts Sweden AB shall ensure that the relevant suppliers are well informed about our Code of Conduct. Suppliers shall ensure that the Code of Conduct is available in the local language to employees involved in production for Trading Gifts Sweden AB. Managers shall be aware of this Code of Conduct and responsible for its application with in their area of responsibility. They shall also be aware of the laws and regulations, applicable at any time and occasion. 7. Audit of Code of Conduct Trading Gifts Sweden AB or its representatives may at any time audit supplier's compliance with our Code of Conduct. The supplier shall fully cooperate with any audit. When a violation of the code of conduct is determined, Buyer will immediately enter into negotiations with the affected suppliers. Together, they will search for solutions and the Buyer will assist in resolving the problem. The solutions must always take into consideration the best interests of the employees. If suitable solutions cannot be found, agreed upon and implemented within a reasonable period of time, this is reasonable grounds for the termination of further business relations. Any actions taken by the Buyer in no way reduce the burden of responsibility on national and local governments, international NGO's and employee representatives to establish an open market trade policy and to stipulate improvements in social conditions.


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