SOCIAL COMPLIANCE REQUIREMENTS (Code of Conduct)

These requirements are designed to set forth the expectations in the operation of factories, including their subcontractors and other business partners that manufacture products for the Company. Compliance by factories and other business partners may be monitored by announced and unannounced visits.

1. No business partner shall employ or otherwise utilize child labor in their contracting, subcontracting or any other business relationship, to manufacture products for the Company. The Company defines “child”, for the purpose of determining child labor, as less than 15 years of age or younger than the age for completing compulsory education in the country of manufacture.
2. Local legal restrictions on work performed by employees, including those restrictions relating to employees under age 18, shall be observed.
3. Employment shall be a voluntary basis, and no prison, convict, slave, indentured, bonded or other forced labor shall be permitted. Sourcing raw materials, components, and products from the Xinjiang Uyghur Autonomous Region is prohibited.
4. Employees shall be treated with dignity and respect, and no employee shall be subject to corporal punishment, threats of violence or any form of physical, sexual, mental, or verbal abuse or coercion.
5. Employees shall be judged on their ability to perform their job, and there shall be no unlawful discrimination in hiring or employment practices.
6. Work hours shall be reasonable and in compliance with local standards and applicable law.
7. Compensation for workers (including piece rate workers) shall not be less than that required by local laws relating to minimum wages, overtime, and mandated benefits (including sick and maternity leave), any deductions from compensation shall be reasonable in accordance with local and other applicable laws.
8. There shall be no interference in the legal exercise of the right of free association.
9. Employees shall be provided with a safe and healthy work environment.
10. Business partners must comply with all applicable environmental laws and regulations.

Compliance with these requirements and with all applicable laws, including local and national codes, rules, and regulations of the country of manufacture, is a requirement of doing business with the Company. Documentation establishing compliance shall be maintained by the factory and/or other business partner and shall be available upon request. The Company may take appropriate action, up to and including termination of any business partner who violates these social compliance requirements.