Codes of Conduct. for. Stormberg A/S

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1 Codes of Conduct for Stormberg A/S November 2012

2 Introduction Stormberg A/S strongly believes in social responsible business. It is therefore important for to take responsibility for all our actions, including the working and environmental situation for those workers taking part in the production of our products. In order to make our position clear to our Suppliers, our own staff, as well as any other stakeholder, we have set up the following codes of conduct (CoC). Principles: The business relationship between Stormberg and its suppliers is based on mutual respect, and all parties shall upkeep a good and constructive dialogue throughout the process. Stormberg requirements Our goal is to use our influence to work for respect for human rights both within the company and towards our business partners. Stormberg shall contribute to continuous training for key personnel and its business partners regarding the goals and principles of this Code of Conduct. Stormberg will, when choosing suppliers, in addition to other competition aspects, consider ethical criteria. Fulfilment of ethical criteria is considered a competitive advantage, and will be taken into consideration when choosing suppliers and vendors. Stormberg, including all employees, do not accept the offer, gift or acceptance of a bribe in any form, including kickbacks, on any portion of a contract payment, or the use of other routes or channels to provide improper benefits to customers, agents, contractors, suppliers, or employees of any such party or governmental officials. Continuous evaluation and improvement of Stormberg internal policies and practices Stormberg will continuously evaluate and, if applicable, improve our own policies and practices in order to facilitate suppliers and subcontractors compliance with this Code of Conduct. Supplier requirements The Suppliers of Stormberg A/S should continuously work for the production of goods and services to take place in compliance with the below mentioned internationally recognised and defined standards. As a general rule, the Suppliers must also ensure that their sub-supplier and any subcontractors comply with these standards. Contract workers, day labourers and casual workers of the Suppliers and subcontractors must be included in this work as well. Under certain political and/or cultural circumstances it may prove difficult to comply with certain standards or to obtain the identities of or contact with all subcontractors. Under such circumstances, one may choose an alternative and appropriate approach. Our Suppliers must allow Stormberg A/S, or those authorized by Stormberg A/S, unrestricted access to its facilities and to all relevant records at all times, whether or not prior notice is provided. 2

3 Suppliers are required to reach the primary goals of this CoC within a reasonable timeframe and this will, as a rule, be a prerequisite for further trading with Stormberg A/S. Failure to improve the conditions will lead to considerations from Stormberg A/S as whether to end the business relationship with the respective Supplier. This will happen only when repeated requests from Stormberg A/S are ignored and/or upon failure to prove promised improvements. Primary goals for production conditions A) Workplace conditions: Employment is freely chosen There shall be no form of forced labour. Workers are not required to lodge "deposits" or identity papers with their employer and are free to leave their employer after prior notice submitted within reasonable time and/or according to national law. The right to organise and to bargain collectively Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. If these rights are limited by law, the employer shall facilitate and under no circumstances hinder parallel means for independent, lawful and free association and bargaining. Workers representatives must not be discriminated against and shall have access to fully carry out their representative functions. Child labour According to the UN Convention of The Rights of Children and ILO Conventions 138 and 182, children under the age of 18 shall not be employed in work that may put their health or safety in danger, including night work. Children under 15 years (16 years in China) shall not be employed in work that may harm their health and/or education. New recruitment of child labour that does not conform to the above conventions will not be accepted. If such child labour is already taking place, work for immediate phasing-out should be initiated. Work will also be put down in order to ensure arrangements for providing subsistence and education for children until no longer of compulsory school age. No discrimination There shall be no discrimination based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation. Systems for protection against sexually intrusive, threatening, insulting or exploitive behaviour and against discrimination or unjust dismissal, e.g. marriage, pregnancy, parenthood, HIV-positive status should be established. No harsh or inhumane treatment All kinds of physical or psychological abuse and the threat of abuse shall be prohibited. This applies to sexual or other harassment as well as other forms of intimidations. Safe and hygienic working conditions A safe and hygienic working environment shall be provided for all workers. Workers shall receive regular health and safety training, and have access to necessary facilities, safetyand first aid equipment at all times. This also includes dormitories when applicable. 3

4 Living wage Wages and benefits paid must enable workers and their dependents to meet their needs for nutritious food and clean water, shelter, clothes, education, health care and transport, as well as allowing for some discretionary income. Conditions in respect to wages shall be agreed upon before entering employment. Deductions from wages as a disciplinary measure shall be strictly limited and not under any circumstances compromise a living wage. Working hours Working hours shall comply with national laws and regulations, and not exceed working hours and spare time in accordance with current international conventions. Imposed overtime shall be limited. Refer International Labour Organization (ILO) for details. Regular employment To every extent possible, work performed shall be on the basis of recognised employment relationships that protect the employees rights and social security as established through national law and practice. Refer China Labour Law of Obligations to employees shall not be avoided through the use of labour-only contracting, sub-contracting, or other labour relations. If these types of contracting or labour relations are to be used under any circumstances, the affected workers are entitled to the same rights as ordinary workers. B) Conditions outside the workplace Property rights and traditional use of resources In cases of conflicts with local societies about the use of land or other natural resources, the parties, must through negotiations secure respect for individual and collective rights to areas and resources based on custom/practice. This also applies to cases where the rights are not formalised. Marginalized groups The production and sourcing of raw materials for production must not contribute to harm the livelihood of marginalized groups, e.g. by occupying large land areas or other natural resources the groups in question are dependent on. Environment Production of Stormberg clothes and sourcing of raw materials must not, in the shorter or longer term, harm the local or global environment in any way that directly or indirectly threatens peoples health, environment or safety. Stormberg s List of Chemicals shall be respected for all Stormberg products. The Supplier should endeavour to carry out means for continuously reduction of electricity, waste water, environmental harmful chemicals, fossil fuel, waste, and other contributors to climate change. Corruption Corruption in any form is not accepted, including bribery, extortion, kickbacks and improper private or professional benefits to customers, agents, contractors, suppliers or employees of any such party or government officials. 4

5 Implementation Both in cases where the minimum standards cannot be met immediately, and in cases where these are already met, the Supplier should work to continuously improve production conditions. This work should be directed towards direct, cost effective measures in fields where there are reason to believe to have genuine potential for improvement. Regarding subcontractors, the Supplier shall, through agreements strive to secure that the Supplier first communicates the primary goals to all subcontractors, then reports on relevant social aspects concerning the subcontractors businesses, and demands that the primary goals are met by subcontractors within a realistic time frame. Subcontracting of whole or part of the main order to another factory is strictly forbidden without prior consent from Stormberg. The Supplier is obliged to inform Stormberg about any sub-contractors in due time prior to production start. Reporting and independent verification of social responsibility Suppliers to Stormberg A/S must report annually on their progress and discrepancy in the work to implement the primary goals and improvement of social conditions. Additional theme-based surveys may also be carried out. The Supplier may also be subject to third party inspection. Stormberg A/S will give further guidance concerning the reports and their format. Animal protection Generally treatment of animals Stormberg discountenance and will not allow any kind of animal abuse in the source for raw materials or in the production of Stormberg products. Mulesing Mulesing is a practice that occurs in some production of wool in Australia. This kind of treatment of sheep shall not occur in Stormberg s supply chain with regards to the production of Stormberg wool products. Fur Stormberg discountenance and will not allow any use of fur, neither from animals nor synthetics fur, in the production of Stormberg products. Leather products Leather products are only to be made from utility animals as pigs, sheep and cattle, where the animal originally was slaughtered for the purpose of meat production. Down Down used in Stormberg products should be made from dead birds that originally was slaughtered for the purpose of meat production. 5

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