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1. Statement of Principles

BIC Graphic a special place to work, with an atmosphere of mutual respect and professionalism. BIC Graphic and its finished product manufacturers have a responsibility to uphold these principles by creating an atmosphere in which each employee knows that he/she is valued as an individual and treated with respect and professionalism. The BIC Graphic Code of Conduct (“Code of Conduct”) enables us to conduct our business, source products and manage our supply chain in a manner that is both profitable and socially responsible.

Implementation of this Code of Conduct enables BIC Graphic to continually improve performance on worker’s rights, labor standards, work place safety and other human rights issues integral to the production process and the overall supply chain.

Compliance with this Code of Conduct is mandatory for all BIC Graphic entities (collectively, “BIC Graphic”) and for all BIC Graphic finished product suppliers (“Suppliers”). Further, as a fundamental part of our Code of Conduct, we align our practices to the ETI Base Code and expect the same of our Suppliers. BIC Graphic reserves the right to immediately terminate its business relationship and cancel all orders with any Supplier or supply chain partner who does not comply with this Code of Conduct.

2. Work Environment

BIC Graphic is committed to treating all its employees with dignity and respect and providing its employees with a safe, healthy, clean and well‐lit work environment including appropriate and adequate facilities and protection from hazardous materials or conditions. BIC Graphic expects its Suppliers to maintain the same standards in their factories and operations. BIC Graphic and its Suppliers must comply with all applicable national, regional, state and local laws, rules and regulations (collectively, “Laws”) governing labor and employment practices and working conditions. If housing is provided for employees, all housing must be maintained in a clean and safe fashion. BIC Graphic strictly forbids the use of cruel and unusual disciplinary practices in the workplace.

3. Engage in Fair and Ethical Employment Practices

Fair Wages: BIC Graphic and its Suppliers must fairly compensate their employees by providing wages, benefits and reasonable working hours in compliance with all Laws of the countries in which BIC Graphic and its Suppliers operate a business. Every worker shall have the right to compensation for a regular work week that is sufficient to meet the worker’s basic needs and provide some discretionary income. BIC Graphic and its Suppliers must compensate their employees at a rate equal to, or greater than, the prevailing local minimum wage, including piece rate workers. In addition to their compensation for regular hours of work, BIC Graphic and its Suppliers should compensate employees for overtime hours at the premium rate required by applicable Law.

Working Hours: No employee shall be required to work more than the regular and overtime hours prescribed by applicable Law. The regular work week shall not exceed 48 hours. Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. Other than in exceptional circumstances, the sum of regular and overtime hours in a week shall not exceed 60 hours.

Child Labor: BIC Graphic will not accept the use of child labor in its operations under any circumstances and will not purchase product(s) from any contract manufacturer that uses child labor. In determining whether a laborer is a “child,” BIC Graphic will refer to the local legal minimum age for employment or the age for completing compulsory education in the country of manufacture. However, the minimum age shall never be younger than 15 years of age. Although BIC Graphic strictly prohibits the use of child labor, BIC Graphic supports the development of legitimate workplace apprenticeship programs for the educational benefit of younger people.

Forced or Compulsory Labor: BIC Graphic will not support trafficking in human beings or accept the use of forced, compulsory, bonded, indentured or prison labor in its operations under any circumstances and will not purchase product(s) from any contract manufacturer or utilize any supply chain partner that supports trafficking in human beings or utilizes forced, compulsory, bonded, indentured or prison labor. Every employee must be a voluntary worker with the freedom to leave the workplace outside of work hours and terminate employment at any time without penalty after notice of reasonable length. Forced prison labor, or work against the will of an employee, including work required as a means of political coercion or punishment for expression of political views is strictly forbidden. No employee shall be subject to any form of harsh or inhumane treatment, corporal punishment, threats of physical or sexual violence or abuse, or other forms of psychological or physical harassment, intimidation, abuse, coercion or sanctions that result in wage deductions, reductions in benefits or compulsory labor. No part of an employee’s salary, benefits, property, or documents shall be withheld in order to force such personnel to continue working.

Discrimination: BIC Graphic employs workers based upon their ability to perform the applicable job responsibilities, not on the basis of personal characteristics, beliefs or any form of discrimination and expects its Suppliers to employ their workers on the same basis. BIC Graphic and its Suppliers shall comply with all anti‐discrimination Laws.

Freedom of Association: BIC Graphic respects the rights of employees to associate, organize and bargain collectively in a lawful and peaceful manner, without penalty or interference, and expects its Suppliers to respect those same rights.

Legal Compliance: BIC Graphic and its Suppliers shall comply with the Laws of the country in which in which BIC Graphic and/or its Suppliers are doing business. BIC Graphic and its Suppliers shall comply with all applicable export and import Laws. Necessary invoices and required documentation must be provided in compliance with applicable Laws. All merchandise shall be accurately and clearly marked with its country of origin in compliance with applicable Laws.

4. Animal Testing

BIC Graphic is committed to providing consumers with the highest quality products that comply with all applicable product safety standards and Laws. BIC Graphic will not purchase products from Suppliers that use animal testing as part of their product development and production. If a BIC Graphic Supplier believes that alternative testing cannot provide sufficient assurance that a product is safe for consumer use, it should advise BIC Graphic in writing.

5. Environment, Health and Safety

BIC Graphic has maintained a long standing commitment to protect the environment and safeguard the health and welfare of its employees, neighbors and consumers. BIC Graphic recognizes that nearly every aspect of a manufacturing business has the potential to impact the environment, human health and safety. It is BIC Graphic’s responsibility to minimize those impacts and develop solutions that protect people and the environment and allow BIC Graphic to maintain the product quality and value that consumers expect. BIC Graphic’s approach is to collaborate with its employees, Suppliers, carriers, customers and consumers to identify, assess and minimize the environmental, health and safety impacts resulting from BIC Graphic’s manufacturing and supply chain operations and the manufacturing and supply chain operations of BIC Graphic’s Suppliers.

6. Monitor Compliance

BIC Graphic conducts regular assessments of its facilities and the facilities of its Suppliers to ensure compliance with this Code of Conduct. All BIC Graphic Suppliers will authorize BIC Graphic’s independent third party monitor to inspect their facilities to ensure compliance with this Code of Conduct.

7. Publication

BIC Graphic and its Suppliers will take appropriate steps to ensure that the provisions of this Code of Conduct are communicated to their employees, including the prominent posting of a copy of this Code of Conduct, in the local language and in a place readily accessible to their employees, at all times.

8. Certification

The BIC Graphic Code of Conduct clearly states BIC Graphic’s commitment to legal, ethical and appropriate working conditions worldwide. The undersigned authorized representative of the below‐named Company has read the standards described in the BIC Graphic Code of Conduct and understands that a continuing business relationship with BIC Graphic is dependent upon adherence to the standards set forth therein. Any failure to follow these standards may result in the cancellation by BIC Graphic of outstanding purchase orders, refusal by BIC Graphic to accept delivery of merchandise and the termination of BIC Graphic’s business relationship with you.