CODE OF CONDUCT

Thomas Pink Ethical Sourcing Policy and Code of Conduct

Thomas Pink has developed over the years long-term relationships with a large number of suppliers. As a result, we have been able to consistently offer 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, Ethical and Environmental 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.

All Suppliers are responsible for the communication and implementation of Thomas Pink’s Ethical Sourcing Policy within their supply chain.

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 the workplace at the end of the working day, and are free to terminate their employment after reasonable notice.

1.3 The Company should not engage in or support in any way trafficking of human beings.

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 company adopts an open attitude towards the activities of trade unions and their organisational activities.

2.3 Worker 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 facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

3. WORKING CONDITIONS ARE SAFE AND HYGIENIC

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 The company observing the code shall assign responsibility for health and safety to a senior management representative, and shall establish systems to detect potential threats to the health and safety of employees. The company shall maintain written records of accidents that occur in the workplace and any company owned accommodation and property.

3.3 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers, or where accidents have occurred.

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

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

3.6 The company shall provide appropriate personal protective equipment at its expense to personal.

3.7 All employees should have the right to remove themselves from imminent serious danger without seeking permission from the company.

4. CHILD LABOUR SHALL NOT BE USED

4.1 The company shall not engage in or support the use of child labour. The term child refers to any person less than 16 years of age, unless the minimum age for work or mandatory schooling is higher by local law in which case the local law and therefore the higher age applies.

4.2 All suppliers must establish, maintain and effectively communicate procedures for the remediation of child labour. In the event that child labour is uncovered in the factory, it will be the responsibility of the company to implement these policies and procedures, providing support, financial and otherwise. These must enable him or her to attend and remain in quality education until no longer a child.

4.3 Under no circumstances shall any young workers be employed at night or in hazardous conditions, or work for more than 8 hours a day. Young workers are defined as any person over the age of a child, but under the age of 18.

5. WAGES AND BENEFITS

5.1 Wages and benefits paid for a standard working week must meet at least legal or industry minimum standards, and shall be sufficient to meets the basic needs of employees as well as providing some discretionary income.

5.2 All employees 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 and benefits 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 without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. WORKING HOURS ARE NOT EXCESSIVE

6.1 Working hours should comply with national laws and industry standards on working hours and public holidays.

6.2 In any event, employees 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 The company shall not engage in or support discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, birth, caste, social or national origin, religion, age, disability, gender, marital status, family responsibilities, sexual orientation, union membership or political affiliation.

7.2 There shall be no pregnancy testing of employees or potential employees.

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, 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 Companies should treat all employees with dignity and respect. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited in either the workplace or any other residence or facility owned by the company.

10. MANAGEMENT SYSTEMS

10.1 The company must assign a senior manager with the responsibility of implementing and complying with the code. Top management should put policies and procedures in place to comply with the code and review on a regular basis.

10.2 The supplier must ensure that their own policy for social compliance and the Thomas Pink Code of Conduct are displayed at the factory in workers language in a prominent, easily viewable location.

10.3 Suppliers are responsible for maintaining records of all suppliers and subcontractors and for ensuring that the Thomas Pink Code of Conduct is complied with in those facilities.

10.4 In the case of announced and unannounced audits, the company shall ensure access to its premises and to reasonable information required by the auditor.

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.

Triman: French Product End of Life Instructions

Thomas Pink takes its responsibility to the Environment very seriously, and part of this is communicating with our customers to ensure that our products and packaging are disposed of correctly at the end of their lives. Our products and packaging may be subject to sorting instructions, and there is a specific French website explaining how to sort all items. Our consumers in France can be sure that we are fully compliant with the required producer responsibility policies.

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Thomas Pink and BCI

Thomas Pink have been working with the Better Cotton Initiative (BCI) since 2015 to incorporate more BCI cotton into our ranges. BCI is a multi-stakeholder, non-profit organisation that exists to make global cotton production better for the people who produce it, better for the environment it grows in, and better for the sector’s future. BCI connects people and organisations from across the cotton sector, from field to store, to promote measurable and continuing improvements for the environment, farming communities and the economies of cotton-producing areas.

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