First Asia Industrial Co., Ltd. Supplier Code of Conduct

The First Asia Industrial Co., Ltd. Supplier Code of Conduct, which is set forth below, outlines First Asia Industrial Co., Ltd. ’s conditions under which its products are being manufactured. First Asia Industrial Co., Ltd. is committed to producing high quality and ethically manufactured products at a good value to its customers. This Code of Conduct applies to our own factories as well as to sub-contractors providing products to First Asia Industrial Co., Ltd. or any of First Asia Industrial Co., Ltd.’s affiliated companies.
This Code of Conduct defines First Asia Industrial Co., Ltd.’s minimum requirements and gives guidelines thereto. It will be subject to regular improvements and First Asia Industrial Co., Ltd. encourages all our factories and sub-contractors to improve their fair and safe labour practices continuously.

1. Own factories and sub-contractors comply with all local laws
All standards set forth in this Code of Conduct are subject to compliance with applicable local law. All factories and sub-contractors must operate in full compliance with the laws of their respective country of manufacture. Own factories and sub-contractors must comply with environmental rules, regulations and standards applicable to their operations, and must observe environmental conscious practices in the locations where they operate.
Own factories and sub-contractors should effectively communicate internal rules and regulations to workers.

2. Employment is freely chosen
The use of forced labour of any kind, including indentured labour, is unacceptable and forbidden.
There are commonly 3 forms of forced labour:

• Prison Labour refers to the work performed by prisoners that is part of their sentence and usually not compensated.
• Indentured Labour refers to the work performed by a worker who is bound to an employer for a certain period of time through a contract.
• Bonded Labour refers to an illegal practice in which employers give high-interest loans to workers who then have to work at low wages to pay off their debt.

First Asia Industrial Co., Ltd. does not tolerate any form of forced labour.

3. Child Labour is not used
Own factories and sub-contractors must not engage in or support the use of child labour as defined in ILO Convention C138.

• Factories and sub-contractors must only employ workers who meet the applicable minimum legal age requirement or at least 15 years of age, whichever is greater, or as an exception, 14 years in countries covered by article 2.4 of the ILO Convention 138.
• All official documentation stating each worker’s age must be available for review. In those countries where official documents are not available to confirm exact date of birth, factories must confirm age using appropriate and reliable assessment methods.

4. No harassment or abuse is allowed
All employees must be treated with respect and dignity.

• Factories and sub-contractors must not engage in or permit physical acts to punish or coerce workers.
• Factories and sub-contractors must not engage in or permit psychological coercion or any other form of non-physical abuse, including threats of violence, sexual harassment, screaming or other verbal abuse.

5. No discrimination is practiced
Factories should only employ workers on the basis of their ability to do the job, not on the basis of their personal characteristics or beliefs.
No person must be subject to any discrimination in employment, including hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social or ethnic origin, maternity or marital status.

6. Wages and benefits are provided to all workers
Own factories and sub-contractors must pay employees at least the minimum wage required by local law or the prevailing local industry wage (whichever is higher) and must provide legally mandated benefits.

• A contract based on local legislation should be established between employee and employer.
• Workers must be paid regularly, on time and the wages must be fair in respect of work performance.
• Factories and sub-contractors must provide all benefits in accordance with the law.
• Factories and sub-contractors must provide annual leave and holidays as required by law.

7. Working hours are not excessive
Own factories and sub-contractors must strive towards that regular working hours or overtime does not exceed the legal maximum according to local law. In addition to their compensation for regular hours of work, employees must be compensated for overtime hours at such rates as is legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate at least equal to their regular hourly compensation rate plus overtime pay.

• While it is understood that overtime is required from time to time in garment production, overtime should be solely voluntary and based on mutual agreement with the workers.
• Factories must record all employee working hours completely and accurately.
• Time records for all workers must be available for review.

8. Freedom of association and collective bargaining are respected
Own factories and sub-contractors must recognize and respect the right of employees to freedom of association and collective bargaining. First Asia Industrial Co., Ltd. does not accept any disciplinary actions from its factories or sub-contractors against workers who choose to peacefully and lawfully organize and join an association.

• Workers are free to lawfully organize and join associations.
• Factories and sub-contractors must not threaten, penalize, restrict or interfere with workers’ lawful efforts to join associations.
• Workers should be able to voice their comments/concerns. A suggestion/complaint box is to be installed inside the work areas for employees.

9. Working conditions are healthy and safe
Own factories and sub-contractors must provide a safe and hygienic working environment to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of factory facilities.

• Factories and sub-contractors must comply with all applicable laws regarding working conditions, including worker health and safety, sanitation, fire safety, risk protection and electrical, mechanical and structural safety.
• The lighting in each workplace must be sufficient for the work performed at all times of the day.
• The temperature in each factory must be tolerable. The factory should be well ventilated with windows, fans or heaters in all work areas for adequate circulation, ventilation and temperature control.
• Factories and sub-contractors must provide potable water for all workers and allow reasonable access throughout the working day.
• Factories and sub-contractors must provide clean and sanitary toilets and should place no unreasonable restrictions on their use.
• Appropriate Personal Protective Equipment (PPE) – such as masks, gloves, goggles, ear plugs and rubber boots – must be made available at no cost to all workers.
• Factories and sub-contractors must place at least one well-stocked first aid kit on every factory floor and should train specific staff in basic first aid. Each factory should have procedures for dealing with serious injuries that require medical treatment outside the factory.
• All workers must be aware of the safety arrangements in the factory such as emergency exits, fire extinguishers, first aid equipment. An evacuation plan should be displayed in the factory, the fire alarm should be tested regularly and regular evacuation drills should be practiced at least once a year.
• Aisles, exits and stairwells must be kept clear and unblocked at all times for orderly evacuation in case of fire or other emergencies.
• Doors and other exits must be kept accessible and unlocked during all working hours for orderly evacuation.
• Factories and sub-contractors must store hazardous and combustible materials in secure and ventilated areas and dispose of them in a safe and legal manner.

10. Documentation, Monitoring, Non-Compliance
Documentation
Own factories and sub-contractors must maintain on file all documentation needed to demonstrate compliance with this Code of Conduct and required laws.

Monitoring / Verification
As a condition of doing business with First Asia Industrial Co., Ltd., own factories and sub-contractors must comply with the First Asia Industrial Co., Ltd. Supplier Code of Conduct. As part of the monitoring process, accredited monitors must be allowed to conduct interviews with workers on a confidential basis.

Non-Compliance
Should we find that a sub-contractor does not comply with our Code of Conduct, we will ask him to take corrective actions in an agreed time limit and if not taken, we will reconsider the business relationship with the supplier leading to termination or our business relationship.

If you have any comments on this Code of Conduct or you would like to report a violation of this Code of Conduct, please do not hesitate to contact:

First Asia Industrial Co., Ltd.
Attn.: Admin Department

Room 709, Zhoudu Building
369 Zuanshi Road
Wafangdian City 116300
Dalian, Liaoning Province
China

Telephone: +86 (21) 5108 3800
Fax: +86 (21) 5633 5820