Thomas Pink Code of Conduct and Ethical Sourcing Policy

Thomas Pink has over the years, developed long – term relationships with a large number of suppliers. As a result, we have consistently offered our customers high quality products. As part of our relationship with our suppliers it is the intention of Thomas Pink to work with suppliers to develop Social and Ethical best practices. The Thomas Pink Ethical Sourcing Policy is communicated to all employees, suppliers and third party contractors involved in the procurement of products. This is to ensure that we take a collective and active role in influencing good practices, in addition to encouraging open and honest dialogue with all our suppliers.

THE ETHICAL SOURCING CODE AND RESPONSBILITES

It is the supplier’s responsibility to communicate and implement our Ethical Sourcing Policy within their supply chain. The supplier must assign a senior manager with the responsibility of implementing the code.

1. EMPLOYMENT IS FREELY CHOSEN

1.1 There is no forced, bonded or involuntary prison labour

1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

2. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING ARE RESPECTED

2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively

2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities

2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace

2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilities, and does not hinder, the development of parallel means for independent and free association and bargaining

3. WORKING CONDITIONS ARE SAFE AND HYGENIC

3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practical, the causes of hazards inherent in the working environment.

3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

4. CHILD LABOUR SHALL NOT BE USED

4.1 Companies shall have no Child Labour, a Child is considered as anyone under the age of 16.

4.2 In the event that Child labour is uncovered during Audits in the factory, it will be the responsibility of the Company to develop or participate in and contribute, to policies and programmes which provide for the transition of any child found to be performing child labour. This must enable him or her to attend and remain in quality education until no longer a child.

4.3 Under no conditions shall any one between the ages of 16 and 18 shall not be employed at night or in hazardous conditions.

5. LEGAL WAGES ARE PAID

5.1 Wages and benefits paid for a standard working week must meet at a minimum the national legal standards

5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. WORKING HOURS ARE NOT EXCESSIVE

6.1 Working hours comply with national laws

6.2 In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

7. NO DISCRIMINATION IS PRACTISED

7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation

8. REGULAR EMPLOYMENT IS PROVIDED

8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice

8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour - only contracting, sub-subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

9. NO HARSH OR INHUMANE TREATMENT IS ALLOWED

9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited

California Transparency in Supply Chains Act of 2010 (SB 657)

Thomas Pink is committed to conducting business in a lawful, ethical, and responsible manner. We expect our vendors to respect and adhere to the same business philosophy in the operation of their businesses. California law requires certain companies doing business in California to disclose their efforts to address the concerns regarding slavery and human trafficking raised by the California Transparency in Supply Chain Act of 2010 (SB657).

Consistent with our commitment, we conduct an ongoing internal assessment of our direct supply chain aimed, among other things, at understanding the potential challenges in a global supply chain of the risks of human trafficking and slavery. In that regard, we review government reports and updates from international trade organisations and non-government organisations dedicated to social compliance issues.

We also have a Vendor Code of Conduct which is based upon principles of ethical business practice and recognition of the dignity of others. The Vendor Code of Conduct specifically prohibits the use of involuntary or forced labor and human trafficking. It also requires compliance with all applicable laws and regulations.

We carry out announced visits to our factories to evaluate compliance with our Vendor Code of Conduct. Thomas Pink is a member of Sedex. Sedex is a not for profit membership organisation dedicated to driving improvements in ethical and responsible business practices in global supply chains. We require all our suppliers to become members. We expect third party audits to be carried out and monitor corrective action plans to ensure they are implemented within a reasonable time frame. Failure to address and correct violations of our Vendor Code of Conduct can result in a reevaluation of our business relationship with such vendor up to and including the termination of such business relationship.

We provide training to employees and management who have direct responsibility for supply chain management of finished goods. Our purpose is to raise awareness of the risks associated with human trafficking and slavery in the supply chain, identifying specific risks, and addressing those risks if human trafficking and slavery are suspected. In 2012 we have set up internal training to create awareness for employees who do not have direct responsibility for supply chain management.