Code of Conduct for Suppliers

 
Code of Conduct for Suppliers

RTW Retailwinds, Inc.

BUSINESS ETHICS and HUMAN RIGHTS PRINCIPLES

RTW Retailwinds, Inc. maintains high standards with regard to social compliance and expects the same commitment from our suppliers. We respect the rights of all employees involved in the production of RTW Retailwinds, Inc. product through fair treatment and just hours/wages. All of our suppliers must agree to comply with RTW Retailwinds, Inc. Code of Conduct for Social Compliance. This code requires suppliers to respect, foster and promote safety, dignity and freedom of their workers and to ensure that their subcontractors do the same.

Definition of Supplier
The term “Supplier” shall mean all vendors, contractors, factories, and other suppliers of materials or services to Retailwinds, Inc. All Suppliers shall ensure that their own suppliers adhere to this Code.

Legal Requirements
Suppliers shall comply with all legal requirements applicable to the conduct of their businesses, including those set out below.

Familiarization and Display of the Code of Business Conduct for Suppliers
Suppliers shall familiarize workers with the RTW Retailwinds, Inc. Code of Business Conduct for Suppliers and display the Code, translated in the local language, at each of their facilities in a place visible and accessible to workers.

Child Labor
Suppliers shall not use child labor. A “child” is defined as a person who is not older than the local age for completing compulsory education but in no event is less than 15 years of age. Suppliers must verify the age of their workers and maintain copies of their workers’ proof of age. Suppliers must follow all applicable laws and regulations regarding working hours and conditions for minors.

Forced Labor
Suppliers shall not use forced or involuntary labor and shall not engage in human trafficking. “Forced” or “involuntary” labor is defined as work or service which is extracted from any person under threat or penalty for its non-performance and for which the worker does not offer himself or herself voluntarily. “Human trafficking” is defined as the act of transporting any person or people with the intent of manipulating or coercing into the state of any manor of prison, bonded or indentured labor.

Harassment and Abuse
Suppliers shall not use corporal punishment or any other form of physical or psychological coercion or intimidation against workers.

Health and Safety
Suppliers shall maintain a clean, safe and healthy workplace in compliance with all applicable laws and regulations. Suppliers shall ensure that workers have access to clean drinking water, sanitary washing facilities and an adequate number of toilets, fire extinguishers, and fire exits, and shall provide a workplace that has adequate lighting and ventilation. Suppliers shall ensure that the aforementioned standards are also met in any cafeteria and/or dormitory which are provided for workers.

Nondiscrimination
Suppliers shall employ workers solely on the basis of their ability to do the job, and shall not discriminate on the basis of age, gender, racial characteristics, maternity or marital status, nationality or cultural, religious or personal beliefs or otherwise in relation to hiring, wages, benefits, termination or retirement.

Hours of Work
Suppliers shall not require workers to work, including overtime, more than 60 hours per week or more than any maximum number of hours per week established by applicable laws and regulations, whichever is less. Suppliers shall guarantee that workers receive at least one day off during each seven-day period.

Wages and Benefits
Suppliers shall provide wages and benefits that comply with all applicable laws and regulations or match the prevailing local manufacturing or industry rates, whichever is higher. Overtime pay shall be calculated at the legally required rate, regardless of whether workers are compensated hourly or by piece rate.

Corrupt Practices
No gratuity, gift or other payment should be given or made to influence government or business decisions. All payments for goods and services should be made only under customary trade terms that reflect their fair value, nor, of course, should any Supplier seek or receive any corrupt payment. All Suppliers must abide by the United States Foreign Corrupt Practices Act in addition to local laws on corrupt practices. While certain minor payments made to non-U.S. government officials made to expedite or secure the performance of certain routine governmental actions may not violate the law, prior written approval from our CEO, CFO and Executive Vice President, Manufacturing must be obtained before making or authorizing any such payment.

Freedom of Association
Suppliers shall respect the right of workers to associate, organize and bargain collectively in a legal and peaceful manner.

Environmental Protection
Suppliers shall comply with all applicable laws and regulations in respect of protecting the environment and maintain procedures for notifying local authorities in the event of an environmental accident resulting from Suppliers’ operations.

Monitoring of Compliance
Suppliers authorize RTW Retailwinds, Inc. and its principals or authorized third parties to conduct scheduled and unscheduled inspections of Suppliers’ facilities for the purpose of ensuring compliance with this Code. During these inspections, RTW Retailwinds, Inc. and its principals or authorized third parties shall have the right to review employee-related books and records maintained by Suppliers and to interview workers.

Corrective Action
When violations are found, RTW Retailwinds, Inc. and the Supplier concerned will agree on a corrective action plan that eliminates the problem in a timely manner. If it is determined that any Supplier is knowingly and/or repeatedly in violation of this Code, RTW Retailwinds, Inc. and its principals shall take appropriate corrective action, which may include cancellation of orders and/or termination of business with the Supplier in question.

Ethical Reporting
To report any violations of RTW Retailwinds, Inc. Code of Conduct for Suppliers, please submit a report to: rtwcompliance@retailwinds.com.

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