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St Regis Group Compliance

Proposition 65 / Supply Chain Code of Conduct

Proposition 65

St Regis Group is committed to providing products and services that meet consumer expectations and are consistent with all applicable local and national laws. This includes conducting all business activity in an ethical and responsible way.

St Regis Group works diligently to apply the highest standards of product safety and market regulatory requirements. All products and decorating inks are required to meet St Regis Group specifications and restricted substance policy. All necessary processes are followed to meet applicable Federal regulations and suppliers are required to obtain necessary Federal approvals or permits, as applicable.

All decorating and printing inks used on products have been tested for compliance within California Proposition 65 (Prop 65) regulations.

St Regis Group requires suppliers to abide by a Restricted Substance List, which includes Prop 65 listed chemicals.

St Regis Group does not knowingly include chemicals that may require a warning. Prop 65 has not fully established “Safe Harbor” levels for all chemicals, and the list is subject to periodic updates.

If it comes to our attention that any product may require a Prop 65 Warning, a short form Warning label will be applied to the product or its immediate packaging.

Regarding products manufactured on or after August 30 2018, if St Regis Group becomes aware that a Prop 65 Warning may be required, we will communicate accordingly.

For any question regarding these policies and procedures, please direct to our Compliance Department: compliance@stregisgrp.com

St Regis Group Core Values

Lawful, compliant and ethical standards at every level of the supply chain.
Providing the safest, highest quality products and services.
Respect for the rights, and respectful treatment of all workers and employees.
Compliance with all environmental laws, and to respect and protect the environment in a sustainable and responsible way.
Healthy and safe workplaces for all workers.
Building and strengthening partnerships based on transparency, collaboration and mutual respect.
Integrity, trust and honesty.

St Regis Group Code of Conduct Standards

As a commitment to St Regis Group Core Values, it is required that all supply chain partners of products, components and materials agree to meet or exceed all of the following “St Regis Group Code of Conduct Standards”.

Social Accountability

No Child Labor: No employment to any person under the age of 15, or under the minimum legal employment age in the country of manufacture, or under required compulsory education age, whichever age is higher.

No Involuntary Labor: No forced, bonded, indentured, prison or any form of involuntary labor.

Freedom of Association and Collective Bargaining: Full recognition and respect for the rights of employees to associate, organize and bargain collectively in a lawful and peaceful manner, without penalty or interference.

Nondiscrimination: No discrimination in hiring and employment practices, including pay, benefits, advancement, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group or ethnic origin.

No Harassment, Abuse or Coercion: Every worker has the right to be treated with dignity and respect. No employee or worker is subjected to threats of violence or any other form of physical, sexual, psychological or verbal harassment and abuse. Nor is such behavior tolerated in any area of the workplace or premises.

Employee Rights: Every employee, or worker, is entitled to full legal rights in the workplace. At a minimum, the rights of employees or workers are safeguarded under local, national and social security laws or regulations, and are consistent with international labor standards under the International Labor Organization (I.L.0.). All complaints are treated seriously and with respect, in confidence, without hostility, reprisal or retaliation, and within full protection of the law, if necessary.

Compensation and Hours of Work

Compensation: Compensation and payment for work is at least the minimum wage or the appropriate prevailing wage, whichever is greater, to comply with applicable legal requirements on wages, and to provide any benefits as required by law or contract. Every worker has a right to wage compensation for a regular work week that is sufficient to meet the worker’s basic needs and to provide some discretionary income. Where this is not achieved, steps are taken to realize a more acceptable level of wage compensation. Wage is remuneration or earnings payable in terms of money for work done or services rendered.

Hours of Work: Workers and employees are not required to work more than regular and maximum overtime hours, as allowed by local or national law in the country of manufacture. The regular work week is 40 hours, not exceeding 48 hours. All overtime work is consensual. Combined regular and overtime hours in a week do not exceed the local or national legal limit, or 60 hours, whichever is less. Overtime is not requested on a regular basis and overtime hours do not exceed 36 hours per month. All overtime work is compensated at the applicable premium rate. Workers receive at least 24 consecutive hours of rest in every seven-day period. Every worker has the right to rest and leisure, including reasonable limitation of working hours and periodic holidays with pay. Daily rest periods, holidays and part-time work comply with all legal standards and national laws. All flexible, irregular and consolidated hour systems are consensual and approved under government law.

Work Environment and Health & Safety

Health and Safety: A healthy and secure workplace is provided in compliance with all applicable local and national laws, and consistent with international standards. The highest standards of workplace and occupational safety are met to prevent worker illness, disease and injury. Policies and procedures are in place (including prevention, reporting and inspection practices) to directly address occupational health and safety concerns. Workers are provided with protective and safety equipment, where necessary. Certified first aid attendees and supplies are always on-hand. Easy access is provided to potable drinkable water, sanitary facilities, fire safety and fire escape routes. Adequate ventilation, lighting, heating and cooling is provided in every worker area.

Accommodations and Dining Rooms: All facilities, including dining rooms and accommodations meet all legal health and safety standards, and are consistent with international standards for human rights. Easy access is provided to potable drinkable water, sanitary facilities, fire safety and fire escape routes. Adequate ventilation, lighting, heating and cooling is provided in all facilities. Any provided accommodations (dormitories and lodgings) are clearly segregated from the manufacture or production area. Workers are not forced to live at factory accommodations. Provided accommodation is affordable and fairly priced. Accommodations do not require workers to leave unreasonable deposits or identity papers, or have unfair rent charges deducted, such that personal choice or freedom to leave is restricted. All accommodations have adequate laundry and kitchen facilities, safe self storage for personal belongings, adequate bathing and toilet facilities, and first aid facilities. All common areas are kept clean; regularly sanitized and waste refuse is managed and disposed of in a sanitary, methodical, regular and responsible way. Workers are accommodated in a way that most respects personal dignity, including privacy, confidentiality, comfort and autonomy. Workers with special needs or requirements are best accommodated, where possible, to avoid undue personal hardship.

Environmental Sustainability

Compliance with all applicable environment laws and regulations, including responsible waste management programs and contaminant clean up. A responsibility to initiate, implement and manage policies that are respectful and safe to the environment and society, that are sustainable and protect energy, water, air, soil, nature, species, biodiversity, fauna, flora, minerals, forests, wildlife, plants and natural resources. Steps are taken to encourage, develop and implement environment friendly technologies, and to reduce waste, reuse where possible and to participate in recycling programs. Respect and recognition is given to the rights of future generations, the needs of society and transboundary environments. Every precaution is taken to prevent noise pollution and protect human health and the environment. Every measure is implemented to reduce greenhouse gas emissions to minimize impact on climate change.

No endangered species of wild fauna and flora are ever procured, exploited or used in production or manufacture. Environmental responsibility includes responsible sourcing of all parts and material including manufacturing, distribution and delivery.

Product Compliance and Safety

Product Compliance: All products, components and materials meet the highest standards of safety and quality and are compliant with “St Regis Group Supplier Quality Agreement”. All items meet safety compliance with applicable U.S.A. and Canada product standards, regulations, certifications or laws, which include (USA) CA Prop 65, FDA, FCC, CPSIA, ASTM, CPSC, 16 CFR, UL or (Canada) CCPSA, and are subject to independent accredited laboratory testing to confirm compliance. Where applicable, all safety certificates and documents provided must be valid, traceable and verifiable. Once all specifications and requirements are agreed, there is no deviation or change permitted to design, component, specification, function or appearance to any product or material.

Restricted Substance Policy: All products, components and materials comply with “St Regis Group Restricted Substance Policy Agreement” to meet global regulations and standards for restricted substances in consumer products. “St Regis Group Restricted Substance Policy” has prioritized a list of substances of high concern to consumers and environment that manufacturers are required to meet the strictest restrictions or eliminate, where possible.

Responsible Sourcing and Manufacturing

Conflict Resources and Minerals: No Conflict Resources, including conflict materials and minerals, are used in any processed materials, parts, components, products, manufacturing process or machinery. No conflict minerals (known as 3TGs) are used including: Cassiterite (for tin), Wolframite (for tungsten), Coltan/Columbite-Tantalite (for tantalum), Gold ore or Diamonds or Cobalt from the following source countries or intermediary trading countries: Democratic Republic of Congo (the “DRC”) Angola, Burundi, Central African Republic, Congo Republic, Rwanda, South Sudan, Zimbabwe, Uganda or Zambia. No conflict resources are used including: rubber from the Ivory Coast (Cote d’Ivoire) or cotton originating in Zambia. Due diligence, reasonable care and investigation of the supply chain and source of raw materials are taken, before making a decision.

Subcontracting: No sub-contracting of the manufacture of products, or process thereof, is permitted without St Regis prior notice and authorization.

Legal and Ethical Practices

Legal: Every activity shall comply with all applicable laws and regulations in the country of business or manufacture.

Anti-Bribery and Anti-Corruption: A zero tolerance policy to corruption, including bribery or any practice intended to reward, or encourage non-compliance with

St Regis Group requirements and/or any necessary legal requirements. No money is offered, anything of value transferred, directly or indirectly (including gifts, incentives or commission) to any representative of St Regis Group, or appointed agent, to obtain improper benefits, advantages or favorable treatment. No facilitation fees are paid to any officials, or any individual to perform or speed up duties to which they are obligated to perform.

Fair Competition: Compliance with all applicable antitrust or competition laws and regulations. Respecting and following free and fair competition practices, and no engagement in any activity that might unfairly limit competition, distort the market or appear to abuse a dominant market advantage. Superior performance is achieved through strength of products, services and people. There is never any discussion, improper agreement or collusion with competitors in regard to pricing, quotes, markets, territories, contracts, quotes or customers.

Monitoring Code Of Conduct and Publication

Monitoring Compliance and Inspections: St Regis Group, its representatives and appointed agents are authorized to monitor and confirm factory compliance with the “Code of Conduct Standards”. This includes announced visits to inspect manufacturing facilities, worker facilities, accommodations and unrestricted access to interview privately any random worker. All records, documents and certificates are openly available, as required, to confirm compliance with St Regis Group code of conduct standards.

Publication: All steps are taken to familiarize workers with the “Code of Conduct Standards”. This includes necessary language translation, publication, distribution and display of the “Code of Conduct Standards” in an area, visible and readily accessible to all workers.

Compliance with the Code of Conduct: Non-compliance and failure to take requested corrective action, or any gross misconduct to the spirit of the “St Regis Code of Conduct Standards” will result in termination or suspension of business by the St Regis Group.

© 2018 St Regis Group