Ethical Products Sourcing Policy

Boost Promo Products Pty Ltd Ethical Sourcing Policy is committed to conducting business and sourcing products in accordance with the highest ethical standards in a responsible manner while complying with all applicable laws.

We have a long history in manufacturing and as such, expect that all our suppliers practice ethical and humane work practices and respect the laws and culture in which they operate.

We are committed to maintaining our leadership role in our industry, by subscribing to high standards of ethical conduct.

Boost Ethical Sourcing Policy

The Boost ESP is directly overseen and reviewed at Director level within our organisation. Compliance with the ESP is regularly audited by our International Factory Manager who personally audits each supplier.

If non-compliance is reported, Boost will undertake remedial action with the supplier immediately and agree to a review of the improvements within a realistic time frame. If the supplier is either unwilling or unable to make these improvements, then a plan is implemented to exit this supplier.

All new suppliers must meet the base standards of our ESP before Boost will work with them. Factory visits will be undertaken to discuss our ethical trading requirements and current compliance with our ESP. Only when Boost is clear that a supplier has shown a genuine commitment to ethical trading will a business relationship commence.

ESP Principles

Boost will only source product from manufacturing facilities that:

1. Do not employ child labor.

We will not work with vendors whose factories utilise child labour. We define child labour as either being below the local minimum working age or the age of 16, whichever is greater.

2. Have a suitable and accountable systems in place to control hours worked,

Factories shall set working hours in compliance with all applicable laws. They shall carry out operations in ways that limit overtime to a level that ensures humane and productive working conditions.

3. Pay staff the appropriate pay and penalty rates.

We seek vendors who work with factories that provide wages and benefits in compliance with

local laws. We encourage our vendors to commit to the betterment of wage and benefit levels to address the basic needs of workers and their families. If meals are provided to staff, then they will be given at suitable meal breaks and in be accordance with local government laws.

4. Provide suitable accommodation.

Any accommodation facility will meet all applicable laws and regulations related to health and safety, including fire safety, sanitation, risk protection and electrical, mechanical and structural safety.

5. Provide a safe work environment.

Workers shall be provided a safe and hygienic working environment that does not expose them to health and safety risks that may cause injury or death. Safety encompasses fire, electrical, structural mechanical and chemical hazards.

6. Have a cleaning program in place to ensure the factory and amenities are

maintained in a clean and tidy state.

Conditions and amenities provided in all production facilities, toilets, meals areas and accommodation if applicable, must be safe, hygienic and consistent with all applicable laws and regulations.

7. Have suitable quality control procedures in place.

Boost produces products that are well-designed, great value, safe and compliant. Vendors guarantee that all goods are made in compliance with all applicable laws, and that all manufacturers and subcontractors also comply with the law.

8. Have training programs in place for all staff.

Workers must receive adequate, recorded training to perform their jobs in a safe manner.

9. Environmental compliance.

Factories shall comply with all applicable local and national environmental laws and regulations. Where such requirements are less stringent than Boost’s own, factories are strongly encouraged to minimise their impact on their surroundings and global resources.

We recognise that there may be times where our expectations are not being met and, while we are committed to working with our suppliers to support continuous improvement, we do reserve the right to terminate business relationships with suppliers that fall short of our expectations or fail to improve over a period of time.

Boost also recognises that global influences on employment conditions and human rights are continually changing therefore we will regularly assess these changes and review our policies accordingly.

Boost Promotional Products Management, January 2020

Code of Vendor Conduct

This Code of Vendor Conduct applies to all factories that produce goods for Boost Promotional Products or any of its subsidiaries, divisions, affiliates or agents. Boost maintains a long-standing commitment to purchase from vendors who maintain the highest Ethical Sourcing Policy labour standards for their employees, respecting the laws and culture in which they operate.

While Boost recognises that there are different legal and cultural environments in which factories operate throughout the world, this Code sets forth the basic requirements that all factories must meet in order to do business with Boost. This Code is based on internationally accepted labour standards, including the International Labour Organisation (ILO)’s core conventions and the Universal Declaration of Human Rights. The Code provides the foundation for Legend Life’s ongoing evaluation of a factory’s employment practices and environmental compliance.

Respect for human rights is a fundamental principle throughout our business practices and standards. We expect our vendors to share our ethical concerns and uphold our standards.

We hold all vendors, manufacturers, contractors, subcontractors and suppliers accountable for abiding by these standards throughout our supply chain and in the manufacture and finishing of products ordered by Boost.

I. Compliance with Laws

Factories that produce goods for Boost shall operate in full compliance with the laws of their respective countries and with all other applicable laws, rules and regulations.

A. The factory operates in full compliance with all applicable laws, rules and regulations, including those relating to labour, worker health and safety, and the environment.

B. The factory allows Boost and/or any of its representatives or agents unrestricted access to its facilities and to all relevant records at all times, whether or not notice is provided in advance.

C. When we refer to “applicable” law in this Code we mean the law, including regulations, judicial decrees and other governmental actions that have the force of law, in effect at each location where a vendor conducts operations with respect to business with Boost.

2. Environment

Factories shall comply with all applicable environment laws and regulations. Where such requirements are less stringent than Boost’s own, factories are strongly encouraged to minimise their impact on their surroundings and global resources.

A. The factory has an environmental management system (EMS).

B. The factory has an environmental emergency plan (EEP) that includes procedures for notifying local community authorities in case of accidental discharge or release or any other environmental emergency.

C. The factory stores hazardous and combustible materials in secure and ventilated areas and disposes of them in a safe and legal manner.

D. Publicly disclose environmental impacts and activities through regular reporting.

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3. Labor

A. Child Labor

Factories shall employ only workers who meet the applicable minimum legal are requirements or are at least 16 years of age, whichever is the greater. Factories must also comply with all other applicable child labour laws. Factories are encouraged to develop lawful workplace apprenticeship programs for the educational benefit of their workers, provided that all participants meet both Boost’s minimum age standard of 16 and the minimum legal

age requirement.

1. Every worker employed by the factory is at least 16 years of age and meets the applicable minimum legal age requirement. If the minimum legal age is higher under local law, the higher age applies.

2. The factory complies with all applicable child labor laws, including those related to hiring, wages, hours worked, overtime and working conditions.

3. The factory encourages and allows eligible workers, especially younger workers, to attend night classes and participate in work-study programs and other government-sponsored educational programs.

4. The factory maintains official documentation for every worker that verifies the worker’s date of birth. In those countries where official documents are not available to confirm exact date of birth, the factory confirms age using an appropriate and reliable assessment method.

5. Only persons at or above the age of 16 may be present in the production areas. Only in the case of a guided tour, conducted by an appropriate factory employee, may persons under the age of 16 enter the work area.

B. Contract Labor Requirements (if applicable)

Factories that recruit or employ foreign contract workers shall ensure that these workers are

treated fairly and on an equal basis with its local workers.

1. Factory has the responsibility and the accountability for ensuring foreign contract workers receive full disclosure and then sign employment contracts in their home countries.

2. Foreign contract workers can return home for any reason and at any time without fear of reprisal and without extraordinary debt. It must allow workers full control of their passport and similar documents and if the worker chooses to allow the factory to keep his/her documents, this must be done in writing and must not be a condition of employment.

3. Factory must pay the same minimum wage to foreign contract workers in the same job category as local workers.

4. The factory must make available to Boost or its representatives upon request, a current list of all foreign contract workers employed at each facility, including the date or arrival, contract term and anticipated date of return.

C. Discrimination

Factories shall employ workers on the basis of their ability to do the job, not on the basis of their personal characteristics or beliefs.

1. The factory hires, employs, promotes, terminates, and provides access to training and retirement to workers without regard to race, colour, gender, nationality, religion, age, maternity, marital status, indigenous status, social origin, disability, sexual orientation, membership in workers’ organisations including unions, or political affiliation.

2. The factory pays workers wages and provides benefits without regard to race, colour, gender, nationality, religion, age, maternity, marital status, indigenous status, social origin, disability, sexual orientation, membership in workers’ organisations including unions, or political affiliation.

D. Forced Labor

Factories shall not use any prison, indentured or forced labor.

1. The factory does not use involuntary labor of any kind, including prison labour, debt bondage or forced labour by governments.

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E. Freedom of Association and the Right to Collective Bargaining

Workers are free to join associations of their own choosing. Factories shall not interfere with workers who wish to lawfully and peacefully associate, organise or bargain collectively. The decision whether or not to do so should be made solely by the workers.

1. Workers are free to choose whether or not to lawfully organise and join associations. If freedom of association and/or the right to collective bargaining are restricted by law, workers shall be free to develop parallel means for independent and free association and collective bargaining.

2. The factory does not threaten, penalise, restrict or interfere with workers’ lawful efforts to join associations of their choosing or to bargain collectively.

3. Workers’ organisations have the right to conduct their activities and elect their representatives without factory interference such as the presence of factory management or factory representatives at organising meetings.

F. Humane Treatment

Factories shall treat workers with respect and dignity. Factories shall not use corporal punishment or any other form of physical or psychological coercion.

1. The factory does not engage in or permit physical acts to punish or coerce workers.

2. The factory does 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.

G. Wages & Benefits

Factories shall pay wages and overtime premiums in compliance with all applicable laws. Workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is the greater. Factories are encouraged to provide wages and benefits that are sufficient to cover workers’ basic needs and some discretionary income.

1. Workers are paid at least the minimum legal wage or local industry standard, whichever is the greater.

2. The factory pays overtime and any incentive (or piece) rates that meet all legal requirements or the local industry standard, whichever is the greater. Hourly wage rates for overtime must be higher than the rates for the regular shift work.

3. The factory provides paid annual leave and holidays as required by law or which meet the local industry standard, whichever is greater.

4. Factories should provide workers with pay slips for each pay period that show regular and overtime hours worked, regular and overtime rates and wages, allowances, bonuses and legal or contractural deductions. Pay slips should be in languages that workers understand.

5. The factory shall not adjust or terminate workers’ contracts for the sole purpose of avoiding the provision of benefits.

6. Workers should be aware of their benefits and understand how their wages are calculated.

H. Working Hours

Factories shall set working hours in compliance with all applicable laws. While it is understood that overtime is often required in a production environment, factories shall carry out operations in ways that limit overtime to a level that ensures humane and productive working conditions.

1. The factory complies with all applicable laws, regulations and industry standards on working hours. Except in extraordinary business circumstances, the maximum allowable working hours in any week shall be the lesser of a) what is permitted by national law, or b) a regular work week of 48 hours plus overtime hours not in excess of 12 hours, unless otherwise permissable under local law.

2. Workers may refuse overtime without any threat of penalty, punishment or dismissal. Overtime must be voluntary.

3. Workers shall have at least one day off in seven.

4. Where a country’s legal code stipulates the regular workday, workweek, rest days, breaks, and/or holidays, factory’s schedules must be in compliance with the law.

5. Factories must record all employee working hours completely and accurately. Time records for all workers must be available for review by employees.

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4. Working Conditions

A. Occupational Health and Safety

Factories shall comply with all applicable laws and regulations regarding working conditions and shall provide workers with a safe and healthy environment.

1. The factory complies with all applicable laws regarding working conditions, including worker health and safety, sanitation, fire safety, risk protection and electrical, mechanical and structural safety.

2. Work surface lighting in production areas – such as sewing, knitting, pressing and cutting – is sufficient for the safe performance of production activities.

3. The factory is well ventilated. There are windows, fans, air conditioners or heaters in all work areas for adequate circulation, ventilation and temperature control.

4. There are sufficient, clearly marked exits allowing for the orderly evacuation of workers in case of fire or other emergencies. Emergency exit routes are posted and clearly marked in all sections of the factory. Emergency exit routes should be marked on the floor with photoluminescent paint, panels or strips.

5. Aisles, exits and stairwells are kept clear at all times or work in process, finished garments, bolts of fabrics, boxes and all other objects that could obstruct the orderly evacuation of workers in case of fire or other emergencies. The factory indicates

with a “yellow box” or other markings that the areas in front of exits, fire fighting equipment, control panels and potential fire sources are to be kept clear.

6. Doors and other exits are kept accessible and unlocked during all working hours for orderly evacuation in case of fire or other emergencies. All main exit doors open to the outside.

7. Fire extinguishers are appropriate to the types of possible fires in the various areas of the factory are regularly maintained and charged, display the date of their last inspection and are mounted on walls and columns throughout the factory so they are visible to workers in all areas.

8. Fire alarms are on each floor and emergency lights are placed above exits and on stairwells.

9. Evacuation drills are conducted at least annually and record of drills should be maintained..

10. Machinery is equipped with operational safety devices and is inspected and serviced on a regular basis.

11. Appropriate personal protective – such as masks, gloves, goggles, ear plugs and rubber boots – is made available at no cost to all workers and instruction in its use is provided.

12. The factory provides potable water for all workers and allows reasonable access to it throughout the working day.

13. The factory places at least one well-stocked first aid kit on every factory floor and trains specific staff in basic first aid. Kits should not be under locked key. The factory has procedures for dealing with serious injuries that require medical treatment

outside the factory.

14. Factory should maintain an up-to-date written record of injuries, including minor injuries and a description of circumstances, injuries and treatment. Injuries can also be sorted by department to focus on how injuries can be reduced.

15. The factory maintains throughout the working hours, clean and sanitary toilet areas, and places no unreasonable restrictions on their use. Toilets should be cleaned at regular intervals.

B. Dormitory (if applicable)

Factories that provide housing for workers shall keep these facilities clean and safe.

1. Dormitory facilities meet all applicable laws and regulations related to health and safety, including fire safety, sanitation, risk protection and electrical, mechanical and structural safety.

2. Sleeping quarters are segregated by sex.

3. The living space per worker in the sleeping quarters meets both the minimum legal requirement and the local industry standard.

4. Workers are provided their own individual mats or beds.

5. Dormitory facilities are well ventilated. There are windows to the outside or fans and / or air conditioners and / or heaters in all sleeping areas for adequate circulation, ventilation and temperature control.

6. Workers are provided their own storage space for their clothes and personal possessions.

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 7. There are at least two clearly marked exits on each floor, and emergency lighting is installed in halls, stairwells and above each exit.

8. Halls and exits are kept of obstructions for safe and rapid evacuation in case of fire or other emergencies.

9. Directions for evacuation in case of fire or other emergencies are posted in all sleeping quarters.

10. Fire extinguishers are placed in or accessible to all floors of the dormitory.

11. Hazardous and combustible materials used in the production processes are not stored in the dormitory or in buildings connected to the sleeping quarters.

12. Fire drills are conducted at least every six months and records are kept in place.

13. Dormitories must have an audible fire alarm that can be heard in all parts of the building.

14. Sleeping quarters have adequate lighting, well maintained, clean and dry.

15. Sufficient toilets and showers are segregated by sex and provided in safe, sanitary, accessible and private areas.

16. Potable water or facilities to boil water are available to dormitory residents.

17. Dormitory residents are free to come and go during their off-hours under reasonable limitations imposed for their safety and comfort. There must be no unreasonable restrictions, such as deposits.

5. Monitoring, Enforcement & Compliance Management

As a condition of doing business with Boost, each and every factory must comply with this Code of Vendor Conduct. Boost will continue to develop monitoring systems to assess and ensure compliance.

Boost Promo Products recognises that an effective and responsible monitoring and enforcement mechanism are crucial to the successful implementation of this Code of Conduct. Factories shall provide designated Boost compliance auditors with physical access to all vendors’ facilities where products are made, in whole or in part. The factory must fully co-operate with the assessment process by providing access to accurate documents and allowing free access to all workers, including home workers.

Factory must not coach workers or threaten or harass them for speaking to the compliance auditors. Factory must allow the compliance auditors to speak with workers confidentially. Workers must have the opportunity to notify Boost anonymously on any workplace quality violations, and they must not receive any retribution for doing so.

If Boost establishes that any factory has violated this Code, Boost may at its discretion either terminates its business relationship and/or require the factory to implement a Corrective Action Plan (CAP). If corrective action is advised but not taken, Legend Life will suspend placement of future orders and may terminate current production.

Boost strongly encourages factories to define and implement a policy for social accountability and to adopt or establish a management system to ensure that the requirements of the Code of Vendor Conduct can be met in a consistent way.

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  AGREEMENT

Vendor and factory must ensure that the management and staff has read and understood the requirements of this Code and effectively communicates the terms of this Code to its workers.

These terms are not subject to negotiation or vendor revision. In order to do business with Boost Promo Products, vendor/factory must accept these terms in whole by signing below. Boost will not be bound by any handwritten or typed changes to this Agreement not specifically approved by Boost in writing.

By signing any Agreement, the vendor / factory certifies that the production facility complies with all requirements contained herein and will continue to be in compliance as long as the vendor / factory is producing goods for Boost.