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INDEX Index Introduction Scope Objective RTM Description Key Definitions A. Minimum Requirements and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers 1. INDITEX Direct Supplier and Sub-Supplier Staff 1.1. INDITEX Product Health and Safety Standard Compliance Manager 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager 2. Traceability Documents 2.1. Purchase Orders to Suppliers 2.2. Documentation and Records B. Minimum Requirements and Best Practices for Mills 1. Mill Staff 1.1. INDITEX Product Health and Safety Standard Compliance Manager 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager 2. General Warehouse Conditions 2.1. Stock Management and Traceability 3. Raw Materials Warehouse 3.1. Composition Analysis 4. Auxiliaries and Dyestuffs/Pigments Warehouse 4.1. CTW and RTM Hard Copies Availability 4.2. Auxiliaries and Dyestuffs/Pigments Information 4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabeling 4.4. Auxiliaries and Dyestuffs/Pigments Weighing 4.5. Dyestuffs/Pigments Specific Storage Conditions 4.6. Auxiliaries Specific Storage Conditions 5. Finished Goods Warehouse 5.1. Finished Goods Identification 5.2. Segregation of CTW or MRSL Non Compliance Finished Goods 6. Work In Progress 6.1. Internal Orders Management 7. Dyeing and Washing 7.1. Auxiliaries and Dyestuffs/Pigments Selection Criteria 1 1 1 2 4 6 7 7 8 8 8 9 11 12 12 12 13 13 14 14 15 15 15 17 18 20 21 22 22 22 23 23 23 23

INDEX 7.2. Dyeing and Washing Recipe 8. Printing 8.1. Auxiliaries and Dyestuffs/Pigments Selection Criteria 8.2. Printing Conditions Selection 8.3. Printing Recipe 8.4. Printing Paste Conservation 9. Water Discharge Effluents 10. Production and Chemicals Control 10.1. Analysis Minimum Requirements for Production Control 10.2. Analysis Minimum Requirements for Chemicals Control 10.3. Instrumentation Minimum Requirements for In-House Analysis 10.4. Outsourced Laboratories 10.5. Control Records 11. CTW Management 11.1. Evaluation of Chemical Suppliers 11.2. Purchase Orders to Suppliers 11.3. Records and Documentation 12. Annexes Annex I. RTM Flow Chart Annex II. INDITEX Direct Suppliers or Sub-Suppliers Commitment to Remove a Mill from the Supply Chain Annex III. Template for Raw Materials Traceability Annex IV. Template for Auxiliaries and Dyestuffs/Pigments Stock Traceability Annex V. Internal Order Template Annex VI. Dyeing/Printing/Washing Recipe Template Annex VII. Analysis to be Performed In-House for Colour Fastness Control of the Production Annex VIII. Analysis to be Performed In-House for ph Control of the Production Annex IX. Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production Annex X. Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production Annex XI. Analysis to be Performed in Outsourced Laboratories for Composition Control of the Production Annex XII. Analysis to be Performed in Outsourced Laboratories for APEO s Control of Chemicals Annex XIII. Analysis to be Performed in Outsourced Laboratories for PFC s Control of Chemicals Annex XIV. INDITEX Proposed Laboratories for Formaldehyde and Arylamines Analysis Annex XV. INDITEX Proposed Laboratories for Simple Fibre Blends Analysis Annex XVI. INDITEX Proposed Laboratories for Complex Fibre Blends Analysis Annex XVII. INDITEX Proposed Laboratories for ph and Colour Fastness Correlation Studies Annex XVIII. Sample Collection Centres Annex XIX. In-House Colour Fastness Analysis Template for Production Control Annex XX. In-House ph Analysis Template for Production Control 23 24 24 25 26 26 27 27 27 27 28 29 31 32 33 33 34 34 36 37 38 39 40 41 42 44 46 47 49 51 52 53 54 56 57 58 59 64 65

INTRODUCTION Introduction INDITEX has developed the manufacturing code Ready To Manufacture (hereinafter, RTM) of general application and mandatory compliance for all suppliers who manufacture, commercialize and/or distribute any article, footwear, accessory and/or raw material yarn, fabric and leather- for any of the INDITEX brands. Thus, it is INDITEX direct suppliers 1 exclusive responsibility to ensure that all RTM requirements are transmitted and properly implemented in all the mills into the scope of this manufacturing code and included in their supply chains. In case you need further information related to RTM, please do not hesitate to contact INDITEX through the Social Responsibility Department (hereinafter, CSR). To this end, send an e-mail to rtm@inditex.com including in the subject the name of the INDITEX brand you are currently working for and/or you have a current purchase order. Scope RTM establishes different requirements which concerns internal processes and facilities of INDITEX direct suppliers, yarn, fabric or leather suppliers, as well as dyeing and printing mills, laundries and tanneries included into their supply chain (hereinafter, the Suppliers). In case that a sub-supplier 2 is included into the supply chain of an INDITEX direct supplier, both sub-supplier and their corresponding yarn, fabric and leather suppliers, dyeing and printing mills, laundries and tanneries will be also subjected to RTM. Note: RTM does not cover, among others, indirect suppliers of trimmings, embroideries and other small components of an article. For this reason, tests to control these articles should be performed by the INDITEX direct supplier. Objective The main objective of RTM is to ensure that all INDITEX Suppliers comply with CTW requirements and the Manufacturing Restricted Substances List (hereinafter, MRSL) resulted from the Zero Discharge of Hazardous Chemicals (hereinafter, ZDHC). To implement the best practices available in textile and leather industry to deliver quality products. Suppliers. 1 Yarn, fabric, leather or garment suppliers who have a direct commercial relationship with INDITEX 2 Supplier who provides goods to an INDITEX direct supplier and may have their own supply chain. They can be traders or vertically integrated suppliers. 1

INTRODUCTION Thus, once these objectives will be achieved, both INDITEX and its Suppliers manufacturing times and costs associated to article reprocessing due to CTW non compliances. RTM is structured in two chapters clearly separated Minimum Requirements and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers and Minimum Requirements and Best Practices for Mills included into their supply chain. Important: In case an INDITEX direct supplier is vertically integrated, 3 they should also comply not only with Minimum Requirements and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers but with Minimum Requirements and Best Practices for Mills as well. Description and implications of minimum requirements and best practices are as follows: Minimum requirements are basic requisites that internal processes of both INDITEX direct suppliers and their supply chains should comply with. Minimum requirements are summarized and highlighted in red colour at the beginning of every section and their compliance is mandatory. Minimum requirement non compliance may result in cancellation or temporary or permanent blocking of INDITEX purchase orders (hereinafter, PO s). Additionally, RTM includes best practices or recommendations to be implemented in the internal processes and facilities of both INDITEX direct suppliers and their supply chains. Best practices are summarized and highlighted in green colour and with a dotted line at the beginning of every section and their compliance is not mandatory but highly recommended. Note: Best practices are focused in those Suppliers with a commitment and engagement beyond the merely complying with RTM minimum requirements. INDITEX direct suppliers should comply, at least, with RTM minimum requirements and take responsibility for the same in all the mills included in their supply chain. To this end, it is not enough with the mere transmission of RTM included into their supply chain. 3 Supplier which participates in all stages of production of an article, from the acquisition of raw materials to its production and commercialization. 2

INTRODUCTION Both INDITEX direct supplier and the mills included into their supply chain should verify RTM implementation by means of a self-audit questionnaire (hereinafter, SAQ) which covers all RTM minimum requirements included in this document and have only two possible answers, Yes or No. In order to pass the SAQ all questions should be positively answered. Since minimum requirements will be different for an INDITEX direct supplier and for the mills included into their supply chain, there are two different SAQ s and both documents should be downloaded by the INDITEX direct supplier from the INDITEX supplier s portal. 4 Distribution of the document to every mill of their supply chain, be INDITEX direct supplier exclusive responsibility. Note: SAQ for the mills included in the supply chain of an INDITEX direct supplier should be filled in for the mill responsible together with a representative of the INDITEX direct supplier. Finally, a Technical Audit will be conducted by external auditor teams nominated by INDITEX in order to check SAQ results. According to this, two situations will happen: INDITEX direct suppliers or sub-suppliers: o Positive (green colour) or Negative (red colour) Technical Audit Result: In both cases and always once all the mills into their supply chain has been audited, a new visit called Global Technical Audit will be carried out in order to: - Inform about the technical audit results obtained by mills into their supply chain. - Check RTM minimum requirements compliance of the INDITEX direct supplier or sub-supplier. - In case of compliance with RTM minimum requirements (green colour) a new visit will periodically happen. - In case of non compliance with RTM minimum requirements (red colour), INDITEX will be informed what may result in temporary or permanent blocking of PO s to this supplier. Mills into the supply chain of an INDITEX direct supplier or sub-supplier: o Positive Technical Audit Result (green colour): The mill will be periodically audited by means of Follow- Up Audits in order to check that they continue to comply with minimum requirements over time. o Negative Technical Audit result (red colour): The auditor will provide a corrective action plan that should be implemented over an agreed time period to ensure mills have the opportunity to meet RTM minimum requirements. Afterwards, a second technical audit will happen that in case of a positive result (green colour) will be followed by the previously described procedure of regular visits or Follow-Up Audits. Conversely, if the result is negative (red colour), INDITEX will be informed what may result in temporary or permanent blocking of PO s to this mill. Note: A RTM flow chart can be found in Annex I. 4 https://extranet.inditex.com/extranet 3

INTRODUCTION Important: Remember that RTM minimum requirements compliance does not exclude full CTW compliance. Manufacturing Restricted Substances List (MRSL): Register of chemical substances that are subject to a usage ban/restriction during the manufacturing process in order to comply with the Zero Discharge of Hazardous Chemicals. Internal order number: RTM considers internal order number to the code assigned to each processing subsets of yarn, fabrics, leather or garments from one initial PO. Raw materials: RTM considers raw materials to yarns, fabrics and leather. Batch: RTM considers a batch to each yarn, fabric, leather or garment delivery from the same supplier, produced at the same mill, using the same chemicals and by means of the same manufacturing process, regardless the number of deliveries and their date. As an example, see the following situations: o 1 PO supplied by two different suppliers will be considered as two batches. o 1 PO supplied by the same supplier but in two different dates will be considered as one single batch only if it was manufactured in the same mill, with the same chemicals and by means of the same manufacturing process. Small Part or Accessory: RTM considers a small part or accessory to an independent element of the o Low manufacturing control. o Low stock traceability. o Independent manufacturing process to the rest of the article. Auxiliaries: RTM considers auxiliaries to the chemicals used during the manufacturing processes of textile and leather articles without comprising dyestuffs and chemical commodities (acids, sodium chloride, sodium sulphate, sodium carbonate, caustic soda, hydrogen peroxide, sodium hydrosulphite, among others). Into this category and in order to comply with RTM requirements, special attention should be paid to the o Dyeing: - Fixers of direct dyes. 4

INTRODUCTION o Printing: - Resins. - Cross linking agents. - Fixers. o Finishing: - Resins. - Adhesives. - Polyurethanes (PU s). - Products for garment effects. - Products for coating. Lot number: assigns to their products for traceability purposes. Dyeing lot: RTM considers a dyeing lot to the quantity of yarn, fabric, leather or garments that have been dyed simultaneously, using the same machinery and the same chemicals. Note: Mixing of different dyeing lots should be avoided during storage and the manufacturing process. Dyeing lot number: traceability purposes. Printing lot: RTM considers a printing lot to the quantity of fabric, leather or garments that have been printed simultaneously, using the same machinery and the same chemicals or until the printing panels are cleaned. Note: Mixing of different printing lots should be avoided during storage and the manufacturing process. Printing lot number: RTM considers a printing lot number to the identification code assign to a printing lot for traceability purposes. Washing lot: RTM considers a washing lot to the quantity of fabric, leather or garments that have been washed simultaneously, using the same machinery and the same chemicals. Note: Mixing of different washing lots should be avoided during storage and the manufacturing process. Washing lot number: lot for traceability purposes. 5

MINIMUM REQUIREMENTS AND BEST PRACTICES FOR INDITEX DIRECT SUPPLIERS AND SUB-SUPPLIERS

1.1. INDITEX Product Health and Safety Standard Compliance Manager. INDITEX Product Health and Safety Standard Compliance Manager in the Different Mills of a Vertically Integrated INDITEX Direct Supplier. 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager. Attendance to INDITEX Training Programs. Workshop for Supply Chain CTW Training. Every INDITEX direct supplier or sub-supplier should have a designated person for all health and safety issues related to INDITEX Product Health Standard, Clear To Wear (hereinafter, CTW). This person should have a deep knowledge of this standard and attend all INDITEX training programs described in the following section 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager. In case that an INDITEX direct supplier is vertically integrated, 5 the INDITEX product health and safety standard compliance manager should ensure that design, purchasing, production and technical area managers are deeply aware of CTW requirements. Note: In case that a sub-supplier 6 is included into the supply chain of an INDITEX direct supplier, both this sub-supplier and their corresponding dyeing and printing mills, laundries and tanneries should also have their corresponding INDITEX product health and safety standard compliance manager. Important: INDITEX product health and safety compliance manager role can be played by one of the workers already hired and does not imply to hire one more person since only a deep knowledge of CTW is needed. Best Practice: Recommended INDITEX product health and safety standard compliance manager knowledge profile should include the following issues: leather processing industry. 5 Supplier which participates in all or major stages of the production of an article, from the acquisition of raw materials to its production and commercialization. 6 Suppliers who provide goods to INDITEX direct suppliers and may have their own supply chain. They can be traders or vertically integrated suppliers. 7

chemical tests for their control. Best Practice: In case that an INDITEX direct supplier is vertically integrated and has several mills in different geographical locations, it is highly recommended to have an INDITEX product health and safety standard compliance manager in all of them. INDITEX product health and safety standard compliance manager should become the in-site internal trainer. In order to be continuously updated, this person should attend to all INDITEX training programs which include: e-ctw&stw program: An educational program launched by the INDITEX Corporate Social Responsibility (hereinafter, CSR) Department in order to inform, train and support all Suppliers about CTW requirements and, help them to reach its requirements. This program is carried out by means of webinars (web conferencing meetings) which allow internet conferencing events in real time with remote locations. Technical Audits (TA s): Visits performed by the most skilled team of experts in textile and leather industry globally to INDITEX Suppliers to assure their CTW and MRSL requirements compliance. Best Practice: The INDITEX product health and safety standard compliance manager should also attend: INDITEX Supplier s Meetings: periodically organized by INDITEX in order to inform, train and aware suppliers in the compliance of CTW and MRSL requirements. Best Practice: INDITEX direct suppliers should organise workshops about CTW and MRSL requirements for both their internal staff and the mills included in their supply chain. Workshops records should be maintained for at least 2 seasons (12 months approximately). 2.1. Purchase Orders to Suppliers. 2.2. Documentation and Records. All PO s sent to suppliers should be in written form and including a remark stating that goods included in the PO should comply with last version of CTW and MRSL. Note: Oral communications should be always avoided. 8

All INDITEX direct suppliers should have a documentation management system in order to ensure production control traceability and their appropriate implementation. According to this, following is a summary of all documents that should be stored and maintained: o List of all mills into their supply chain, including: - Mill/sub-supplier legal company name. - Mill/sub-supplier full address: - Address, city, zip code, state/region and country. - Activity of the mill (printing, washing, dyeing, tannery, confectionery, accessories supplier, among others). - INDITEX brand(s) the mill is working for. - - INDITEX product health and safety standard compliance manager: - Name, job title and contact details (phone and/or fax number and e-mail address). Important: Please, note that it is mandatory to disclose the mills that will be used for every INDITEX PO received by means of section Orders in the INDITEX suppliers portal. 7 Additionally, and in order to have your supply chain information always updated, it is highly recommended to register any change on it without waiting for an INDITEX PO. mills and suppliers used in the last two sessions (approximately 12 months). he mills and suppliers into their supply chain. o INDITEX direct suppliers or sub-suppliers should get from every mill included into their supply chain a written commitment, stating that they know and understand both CTW and MRSL and that all the goods provided will comply with their requirements. o Once an INDITEX direct supplier or sub-supplier decides to remove one mill from the supply chain be signed and provided by the top management (see an example in Annex II). Note: In the same way, every time an INDITEX direct supplier or sub-supplier decides to include a new mill into the supply chain, it should be done by means of section Orders in the INDITEX Suppliers portal. Thus, as soon as this notification is received, RTM implementation will start as a previous requirement to start working with this mill. 7 https://extranet.inditex.com/extranet 9

o Every INDITEX direct supplier or sub-supplier should have a hard copy of CTW, RTM and SAQ onsite. Additionally, in case the direct supplier has been subjected to one or several technical audits, all audit reports should be maintained. direct supplier or sub-supplier to the mills included into their supply chain. supplier or sub-supplier to the mills included into their supply chain.. Remember: Initially, INDITEX direct supplier or sub-supplier should provide the required information for the current season. Eventually, it should be updated until covering the last 2 seasons (approximately 12 months). Remember: In case an INDITEX direct supplier or sub-supplier is vertically integrated, they should also comply with the Minimum Requirements and Best Practices for Mills which will be shown in the following chapter of this document. Remember: RTM compliance does not exclude full CTW compliance. According to this, all INDITEX direct suppliers and sub-suppliers should ensure that finished goods comply with CTW requirements previously to their shipment. 10

TÍTOL MINIMUM REQUIREMENTS AND BEST PRACTICES FOR MILLS 11

1.1. INDITEX Product Health and Safety Standard Compliance Manager. 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager. Attendance or Participation in INDITEX Training Programs. Workshop for internal CTW Training. Every yarn, fabric or leather supplier, dyeing and printing mill, laundry and tannery into the supply chain of an INDITEX direct supplier or sub-supplier should have a designated person for all health and safety issues related to INDITEX. This person should have a deep knowledge and understanding of the INDITEX Product Health Standard, Clear To Wear (hereinafter, CTW) and attend all INDITEX training programs that will be described in the following section 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager. Additionally, this person should also ensure that purchasing, production line and technical area managers are deeply aware of CTW requirements. Important: INDITEX product health and safety compliance manager role can be played by one of the workers already hired and does not imply to hire one more person since only a deep knowledge of CTW is needed. Best Practice: Recommended INDITEX product health and safety standard compliance manager knowledge profile should include the following issues: processing industry. tests for their control. The INDITEX product health and safety standard compliance manager should become the in-site internal trainer for the rest of the workers. In order to be continuously updated, this person should attend to all technical audits carried out in the mill: Technical Audits (TA s): Visits performed by the most skilled team of experts in textile and leather industry globally to INDITEX Suppliers to assure their compliance of CTW and MRSL requirements. 12

Best Practice: participate in the following training programs: INDITEX Supplier s Meetings: periodically organized by INDITEX in order to inform, train and aware suppliers in the compliance of CTW and MRSL requirements. e-ctw&stw program: An educational program launched by the INDITEX Corporate Social Responsibility (hereinafter, CSR) Department in order to inform, train and support all Suppliers about CTW requirements and, help them to reach its requirements. This program is carried out by means of webinars (web conferencing meetings) which allow internet conferencing events in real time with remote locations. Best Practice: Mills should organise workshops about CTW requirements and the MRSL for internal staff. Workshops records should be maintained for at least 1 year. This section comprises all minimum requirements and best practices common to all warehouses involved be also covered. 2.1. Stock Management and Traceability. Printed Traceability Documents. Use of Location Markers. auxiliaries or their batch number for raw materials. Incoming raw materials (yarn, fabrics or leather) in the warehouse should be always registered including all information shown in Annex III. Stock of auxiliaries and dyestuffs/pigments should be always updated. To do so, their stock should be monthly registered including all information shown in Annex IV. Note: In case stock management is automated, it should be printed once a month and maintained for at least 2 seasons (12 months approximately). Important: Annex III and Annex IV templates are for guidance only. Alternatively, any other format which includes, at least, all the information required in these templates can be used. Note: Traceability of products which could be stored outdoor (raw materials and auxiliaries) should be always ensured, even under extreme weather conditions. 13

Best Practice: In order to avoid confusions, all labels and traceability documents should be always typed. To ensure the identification of hides, skins and leather in tanneries, traceability codes should also be stamped on their surface. Goods properly identified Goods without proper identification Best Practice: Location markers should be used for proper location and identification of goods. Goods properly identified with location markers 3.1. Composition Analysis. Along with every batch of raw materials (except leather), a compositions analysis should be provided. This analysis should be performed by the raw material supplier according to section 10.1. Analysis Minimum Requirements for Production Control. 14

one or several (depending on the size of the batch received) internal order numbers in order to track the raw materials as long as they are being processed. Internal order number should be incorporated to an internal order template including all information shown in Annex V. To ensure an appropriate traceability, this template should accompany the goods along their manufacturing process and storage. Important: Annex V template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. 4.1. CTW and RTM Hard Copies Availability. CTW and RTM Hard Copies Availability in Close Proximity to Chemicals. 4.2. Auxiliaries and Dyestuffs/Pigments Information. SDS and TDS Availability in Close Proximity to Chemicals. Translation of SDS and TDS Key Information into Local Language. 4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabelling. 4.4. Auxiliaries and Dyestuffs/Pigments Weighting. Auxiliaries and Dyestuffs/Pigments Auto Dosing System. Auxiliaries and Dyestuffs/Pigments Weighing Responsible Person. Balance Proximity to Auxiliaries and Dyestuffs/Pigments. Auxiliaries and Dyestuffs/Pigments Balance Calibration. 4.5. Dyestuffs/Pigments Specific Storage Conditions. Dyestuffs/Pigments Warehouse Door or Polymer Curtain. Proper Opening of the Dyestuff/Pigments Containers. 4.6. Auxiliaries Specific Storage Conditions. CTW and RTM hard copies should always be available on-site. Best Practice: CTW and RTM hard copies should be stored close to auxiliaries and dyestuffs/pigments for ease of reference if necessary. from the chemical supplier. Labels should include lot number and product and supplier/distributor names. 15

Chemicals properly identified Dyestuff without proper identification (lot number is not available) In case, a chemical does not include all this information or it does not comply with CTW and/or MRSL requirements, it should be considered as a CTW and/or MRSL non compliance product, highlighted and stored segregated. Dyestuff which does not comply with CTW requirements perfectly identified and segregated Auxiliaries which does not comply with CTW requirements perfectly identified and segregated Note: In the same way, to remove totally or partially their original label information will be also not accepted. Dyestuff containers with hand written labels and which original labels have been removed 16

Safety Data Sheet 8 (SDS) and Technical Data Sheet 9 (TDS), completed and updated, should be included. Additionally, in case of any update in the SDS or TDS, it should be sent again by the chemical supplier. Note: Every SDS should be checked to ensure the product does not contain a restricted substance included in the MRSL or this substance is above CTW requirements. Best Practice: access if necessary. Best Practice: issues from SDS should be translated into local language to ensure all workers understanding. Appropriate signs and pictures can be included to highlight key points. SDS key issues translated into local language and including signs to reinforce the message Auxiliaries and dyestuffs repackaging and relabeling should be avoided and carry out only in case it is strictly necessary. If this happens, the new containers should include a label that ensures traceability to the original one. be updated with the new information. 8 Document which describes the hazards associated with a chemical product. They list hazardous ingredients (i.e. formaldehyde), types of hazards present and ways that workers should handle the materials and protect themselves. 9 Document which summarizes the application mode and other technical characteristics of a product. 17

Repackaging of dyestuffs with the original labelling attached at their upper lid Repackaging of dyestuffs without proper identification Important: case of auto dosing systems minimize the mix of different lot numbers as far as possible. In order to avoid cross contamination during auxiliaries and dyestuffs/pigments weighing, next indications should be followed: independently. Only, once that each and every product has been weighed, they can be put together in one single container. Correct Practice Incorrect Practice y auxiliary, dyestuff or pigment should have its own weighing accessories (jars, buckets, spoons, 18

Dyestuff container with its weighting spoon properly identified Auxiliaries without their own weighting accessories Use of original auxiliaries containers Use of no original auxiliaries containers modified by including a tap in their bottom surface for proper weighing and to avoid any risk of contamination. Balance in a clean, dry and flat surface Balance under inappropriate conditions 19

Note: In case the balance is equipped with a level indicator, make sure that it is in the position which implies that this instrument is well-balanced. Best Practice: Auto dosing systems are highly recommended since they can reduce the risk of exposure, spillage and wastage of auxiliaries, dyestuffs and pigments. Best Practice: trained and designated person and if possible, in a segregated place from their warehouse. Best Practice: to the balance as carrying small product amounts over large distances can lead to inaccuracy and potential cross contamination. Best Practice: Balance needs to be calibrated according to manufacturer recommendations. Once calibrated, records should be properly maintained. according to what was previously described in section 2. General Warehouse Conditions. Additionally, dyestuff and pigment containers should be always stored closed and will be opened only for weighing. Proper dyestuff storage Improper dyestuff storage Best Practice: Since p pigment warehouse should be equipped with a door or at least, a plastic polymer curtain in order to avoid the contamination of other areas of the mill. 20

Dyestuff warehouse equipped with a door Dyestuff warehouse equipped with a polymer curtain Best Practice: the upper side of the container can be used as its lid. Dyestuff containers properly opened Dyestuff containers improperly opened To avoid potential cross contamination, auxiliaries in solid and liquid form should be stored in segregated areas. Liquid and solid auxiliaries stored segregated Liquid and solid auxiliaries improperly stored 21

MINIMUM REQUIREMENTS AND BEST PRACTICES FOR MILLS 5. Finished Goods Warehouse 5.1. Finished Goods Identification. 5.2. Segregation of CTW or MRSL Non Compliance Finished Goods. 5.1. Finished Goods Identification Finished goods should be stored indoor, avoiding direct contact with the floor and walls and according to what was previously described in section 2. General Warehouse Conditions. Additionally, finished goods should be identified with at least, their internal order number which should be traceable to the corresponding internal order template and that should include all the information shown in Annex V. Important: Annex V template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. Finished goods storage with an appropriate traceability and avoiding direct contact with the floor Finished goods without proper traceability and in direct contact with the floor 5.2. Segregation of CTW or MRSL Non Compliance Finished Goods In the case that despite all efforts made during the manufacturing process you have any CTW or MRSL non compliance products, they should be stored in segregated areas in order to guarantee their destruction or reprocessing, according to customer instructions. CTW non compliance finished goods highlighted in red colour and store segregated 22

6.1. Internal Orders Management. In order to have proper traceability throughout the entire manufacturing process, goods should be always accompanied by their corresponding internal order template (see an example in Annex V) which should include all the information related to the goods that are being manufactured and the different processes they are being subjected to. Important: Annex V template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. 7.1. Auxiliaries and Dyestuffs/Pigments Selection Criteria. 7.2. Dyeing and Washing Recipe. Liquor Ratio Control. Dyeing and Washing Parameters Automated Control Machinery. Indirect Steam Dyestuff/Pigments Dissolution. Auxiliaries, dyestuffs and pigments selection is an important issue to comply with CTW and MRSL requirements. For this reason, every mill should take into account both documents before purchasing chemicals. In order to facilitate an appropriate selection of auxiliaries, dyestuffs and pigments, INDITEX provides its Suppliers with The List, 10 a register of chemicals from internationally reputed suppliers with high technical Note: In the case of fur and leather industry, special attentions should be paid to chromium (Cr) and particularly to Cr (VI) which should not be present in any of the salts or solutions used during the tanning process. Additionally, taking into account that Cr (III) can be oxidized to Cr (VI), high oxidizing power products, unsaturated fats or ph over 6.5 should be avoided. include all the information shown in Annex VI. 10 You can download this document directly from the INDITEX supplier portal (https://extranet.inditex.com/extranet). 23

Important: Annex VI template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. Best Practice: In order to obtain an appropriate reproducibility and colour fastness results, liquor ratio 11 should be controlled during dyeing. Best Practice: All dyeing and washing machinery should be microprocessor based controlled in order to control all key parameters of the process, especially temperature and time, to ensure appropriate reproducibility and colour fastness results. Best Practice: To prevent metals transportation from the piping system to the articles that are being manufactured, direct hot steam dyestuff dissolution should be avoided and replaced by indirect steam along with a stirring facility to provide heat uniformity. 8.1. Auxiliaries and Dyestuffs/Pigments Selection Criteria. 8.2. Printing Conditions Selection. Resin Curing Maximum Temperature in Accordance with TDS of the Resin with the Highest Curing Temperature. 8.3. Printing Recipe. Printing Parameters Automated Control Machinery. Indirect Steam Dyestuff Dissolution. 8.4. Printing Paste Conservation. Proper Storage of Printing Pastes. Auxiliaries, dyestuffs and pigments selection is an important issue to comply with CTW and MRSL requirements. For this reason, every mill should take into account both documents before purchasing chemicals. In order to facilitate an appropriate selection of auxiliaries, dyestuffs and pigments, INDITEX provides its Suppliers with The List, 12 a register of chemicals from internationally reputed suppliers with high technical skills Note: In the specific case of printing and whenever possible, polymeric materials (TDI and MDI based polyurethane products) should be avoided since subjected to high temperatures or by side reactions between diisocyanate with water may promote the formation of forbidden arylamines. 11 Weight of greige fabric or garment to bath proportion. 12 You can download this document directly from the INDITEX Supplier Portal (https://extranet.inditex.com/extranet). 24

Printing conditions, especially temperature and resin curing time, are critical since inappropriate processes can lead to arylamines and formaldehyde promotion and colour fastness decrease. For this reason, every printing mill should pay special attention to different issues throughout the printing process and follow the next steps: Documents related to the chemicals used (SDS and TDS): o To check by means of the SDS that content of formaldehyde or any other substance complies with CTW requirements for the application in use. Note: Remember that formaldehyde or any other substance contents shown in a SDS are individual and global contributions of all the products included in a printing recipe could lead to a CTW non compliance. o To check that chemical application conditions carefully follow application mode instructions provided in the corresponding TDS. Machinery for printing: o To check that machinery used for printing is able to reach, maintain and control all parameters o To check that the curing oven have an appropriate steam extraction system which avoids potential formaldehyde condensations and contamination of goods. Appropriate printing resin curing by means of with temperature and time control and an adequate steam extraction Inappropriate printing resin curing without temperature and time control and no steam extraction Curing process: curing and intermediate drying steps (if any) temperatures are in accordance with those initially planned. 25

Note: Temperatures should be always in accordance with chemicals TDS information. In case this order to know maximum temperature for every step. However, temperature of intermediate drying steps higher than curing resin temperature will not be allowed. o To avoid, whenever possible, the use of ready to use products or in-house mixtures of resins with different curing temperatures. Best Practice: In case ready to use products or in-house mixtures of resins with different curing temperatures are used, highest temperature for curing should be always below the maximum curing temperature of the resin with the highest curing temperature. Important: The use of heat guns or any other device without a proper control of both time and temperature the print is subjected to should be always avoided. information shown in Annex VI. Important: Annex VI template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. Best Practice: All printing machinery should be microprocessor based controlled in order to control all key parameters of the process, especially temperature and time, to ensure appropriate reproducibility and colour fastness results. Best Practice: To prevent potential contamination and metals transportation from the piping system to the replaced by indirect steam along with a stirring facility to provide heat uniformity. All additives used to preserve printing pastes should comply with CTW and MRSL requirements. For this reason, make sure you strictly follow section Best Practice: To prevent cross contamination and to achieve better traceability, printing paste containers should be stored closed, properly identified and in a systematic manner. 26

Printing pastes with good traceability Printing pastes without proper traceability 9. 9.1. Water Discharge Effluents Control. to check compliance of environmental legislation and MRSL. If necessary, the auditor will provide a corrective action plan that should be implemented over an agreed time period. 10.1. Analysis Minimum Requirements for Production Control. 10.2. Analysis Minimum Requirements for Chemicals Control. 10.3. Instrumentation Minimum Requirements for In-House Analysis. 10.4. Outsourced Laboratories. 10.5. Control Records. RTM considers that to comply with CTW requirements, both mills and vertically integrated INDITEX direct suppliers should have a procedure of production control and supervision. In this regard, RTM aims to become a reference in the development and implementation of control procedures by means of a set of analysis minimum requirements that every mill working for an INDITEX direct supplier should comply with. Depending on the complexity of the analysis, it will be performed in-house or outsourced: Analysis to be performed in-house: o ph (except for tanneries where this test is excluded). o Colour fastness: - To perspiration. - To water. 27

- To rubbing (dry and wet). - To saliva (only for baby garments). Note: In the case of colour fastness analysis, two specific situations should be considered: o Tanneries and positional printing mills where fluorescent pigments are not being used: They only need to perform dry and wet colour fastness to rubbing. Colour fastness to water, perspiration and saliva are excluded. Important: Once a month, every mill should send one of the samples previously analyzed in-house to one external lab as a correlation study, in order to check that results obtained in-house are correct. Note: See section 10.4. Outsourced Laboratories to know the requirements that an external laboratory should comply for acceptance of the results provided. Nota: For more information about the main issues related to colour fastness and ph in-house analysis see Annex VII and Annex VIII, respectively. Analysis to be outsourced: o Arylamines. o Formaldehyde. o Composition. Note: For more information about the main issues related to outsourced analysis for production control see, and Additionally, you may be required by the INDITEX CSR Department to be enrolled in a set of mandatory programs of reasonable and responsible analysis of production such as: According to MRSL, the use of products containing APEO s during the manufacturing process is not allowed. For this reason, auxiliaries, dyestuffs and pigments should be APEO s free. 28

Note: A chemical will be considered as APEO s free if its APEO s content is below 100 ppm. For this reason, all chemicals likely to have APEO s should be subjected to a supervision and control according to Similarly, according to MRSL and the commitment undertaken by INDITEX to remove long chain PFC s (C8 s- should be carried out. Owing to APEO s and PFC s analysis complexity, tests should be performed in external laboratories according to section 10.4. Outsourced Laboratories. Since ph and colour fastness analysis should be carried out in-house, every dyeing and printing mills, laundries and tanneries, included into the supply chain of an INDITEX direct supplier or sub-supplier should have well ph meter with temperature probe Shaker Note: ph measurements cannot be performed with ph indicator papers or indicator solutions due to their inaccuracy and that they do not take into account potential ph changes due to temperature variations. 29

Crockmeter for textiles Perspirometer Balance Oven (*) Colour fastness grey scales (*) Light box 13 13 In the case of laundries without dying processes and positional printing mills, to have a light box will not be considered as a minimum requirement but a highly recommended best practice. 30

Mono or Multifiber species Note: As previously mentioned, in the case of tanneries, only dry and wet colour fastness to rubbing is mandatory. For this reason, only instrumentation marked with (*) is mandatory for them. Please note that in the case of leather, both crockmeter and the cloth for rubbing are different from textiles. (*) Crockmeter for leather (*) Wool felt cloth for rubbing In order to obtain correct and reliable analytical results, the selection of an external laboratory is critical. According to this outsourced, laboratory selection should take into account the following issues: tests they are performing for their customers. 14 In this regard and in order to ease the selection of the external laboratories, INDITEX provides you a list of approved laboratories which are able to perform arylamine and formaldehyde tests (see ). 14 Reasonable analysis times comprises from 3 to 8 working days depending on garment/fabric complexity. 31

provides you two different set of approved laboratories for composition analysis: 15 (see ). 16 (see ). In the case of ph and colour fastness correlation studies previously mentioned in section 10.1. Analysis Minimum Requirements for Production Control, INDITEX provides you a list of approved laboratories to carry out these analyses (see ). Finally, in order to facilitate the shipment of samples to the laboratories, INDITEX provides you a set of sample collection centers worldwide where you can send the sample to be analyzed (see ). Afterwards, the sample collection center where the sample is received assigns the laboratory where the analysis will be carried out. Note: Please note that samples sent to a collection center will be sent to laboratories belonging to the same analytical service provider. For this reason, please check before sending the samples that the chosen analytical service provider has at least one laboratory capable to carry out the tests requested. Both in-house analysis templates and outsourced analysis test reports should be maintained for at least 2 seasons (12 months approximately). Related to in-house ph and colour fastness analysis for production control, test results should be registered including all information shown in and Important: and templates are for guidance only. Alternatively, any other format which includes, at least, all the information required in these templates can be used. 15 16 o Plastic materials (polyurethane, polystyrene or PVC coatings, among others). o Feathers/Down. 32

11.1. Evaluation of Chemicals Suppliers. 11.2. Purchase Orders to Suppliers. 11.3. Documentation and Records. All mills working for an INDITEX direct supplier should create an internal written procedure in order to evaluate every chemical supplier and their corresponding products. Note: In case of new suppliers, this procedure should be implanted before starting the commercial relationship. In order to consider a chemical supplier as suitable for RTM, they should be able to provide the following Official and signed commitment stating that along with every chemical delivery, the following information will be provided: o Shipment delivery notes including: - Shipment delivery note number. - Supplier name (original manufacturer or distributor). - Customer name. - Product name. - Delivery date. - Product name. - Supplier name (original manufacturer or distributor). - Product lot number. Note: Please, remember that along with the reception of a chemical product for the first time, its Safety Data Sheet (SDS) and Technical Data Sheet (TDS), completed and updated, should be included. Additionally, in case of any update, SDS and TDS should be sent again by the chemical supplier. CTW non compliance suppliers. In the same way, every time a mill stops working with a chemical supplier because they do not comply with any of these requirements, this supplier should be included in the CTW non compliance suppliers list. 33

Note: Prior to start working with a new supplier, CTW non compliance suppliers list should be checked to make sure that the new supplier is not included in this list. All PO s sent to suppliers should be in written form and including a remark stating that goods included in the PO should comply with last version of CTW and MRSL. Note: Oral communications should be always avoided. Every mill included into the supply chain of an INDITEX direct supplier should have a documentation management system in order to ensure production control traceability. see an example in Annex III). see an example in Annex IV). see an example in Annex V). see an example in Annex VI). see examples in shown in section 11.1. Evaluation of Chemical Suppliers including: 34

Important: Initially, mills into the supply chain of an INDITEX direct supplier should provide the required information for the current season. Eventually, it should be updated until covering the last 2 seasons (approximately 12 months). 35

ANNEXES

12. Annexes Annex I. RTM Flow Chart DIRECT SUPPLIERS RED TECHNICAL AUDIT RED GLOBAL TECHNICAL AUDIT RED GREEN INFORM TO INDITEX GLOBAL TECHNICAL AUDIT RTM IMPLEMENTATION SAQ GREEN TECHNICAL AUDIT RED GREEN GLOBAL TECHNICAL AUDIT GLOBAL TECHNICAL AUDIT RED GREEN RED INFORM TO INDITEX GLOBAL TECHNICAL AUDIT INFORM TO INDITEX RED TECHNICAL AUDIT RED TECHNICAL AUDIT II RED GREEN INFORM TO INDITEX FOLLOW-UP AUDIT SAQ RED INFORM TO INDITEX MILLS GREEN TECHNICAL AUDIT RED GREEN TECHNICAL AUDIT II GREEN FOLLOW-UP AUDIT FOLLOW-UP AUDIT PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 37

Annex II. INDITEX Direct Suppliers or Sub-Suppliers Commitment to Remove a Mill from the Supply Chain Notification that should be sent by the supplier when they want to remove a mill from the supply chain initially provided. I hereby confirm that, After consideration of the results obtained by in the Technical Audits, kindly note that we would like to remove them immediately from our supply chain. I will appreciate your further update of our supply chain based on the information initially declared. Thank you very much in advance Best regards. 38