DEFINITION AND STANDARDS

Equal Hands LLC is committed to legal compliance and ethical business practices in all of our operations worldwide. We choose business partners who we believe share that commitment. We have placed or are considering placing, one or more orders with your company for the manufacture of apparel, bags, jewelry, accessories, and/or beauty products (our “Products”) or for the performance of services with regard to the manufacture of our Products. We would like to call your attention to Equal Hands policy regarding legal compliance and ethical business practices.

We have defined “business partners” as vendors, contractors, and suppliers who provide labor and/or material that is used in the manufacture of our Products, regardless of Equal Hands’ role as purchaser or sourcing agent.

In our purchase arrangements, business partners must observe all applicable laws of their country, including laws relating to employment, discrimination, the environment, and safety in the fields related to our Products. Moreover, business partners must comply with applicable U.S. Customs laws relating to the import of Products, including country of origin labeling, Product labeling, and testing of the fabrics and materials used in the Products. If  local or industry practices exceed U.S. legal requirements, this higher standard should be met.

Equal Hands standards are summarized as follows:

• Child Labor: Our business partners must not use child labor. The term “child” refers to a person younger than 15 (or 14 where local law allows) or, if higher, the local legal minimum age for employment or the age for completing compulsory education. Employers employing young persons who do not fall within the definition of “children” will also comply with any laws and regulations applicable to such persons.

• Forced or Compulsory Labor: Our business partners must not utilize forced labor, including prison labor, bonded labor, indentured labor, or other compulsory labor.

• Coercion, Harassment and Abuse: Our business partners must treat each employee with dignity and respect, and will not use corporal punishment, threats of violence, or other forms of physical, sexual, psychological or verbal harassment or abuse.

• Freedom of Association / Collective Bargaining: Our business partners must recognize the right of employees to associate freely and bargain collectively.  This includes the right of employees to join trade unions.  Our business partners must not threaten, penalize or discriminate against or otherwise interfere with employees exercising these rights.
  
  
• Nondiscrimination: Our business partners must not discriminate in hiring and employment practices (including salary, benefits, advancement, discipline, termination or retirement) on the basis of race, religion, age, nationality, social or ethnic origin, marital status, sexual orientation, gender, political opinion or disability.

• Health and Safety: Our business partners must share our commitment to providing a safe and healthy workplace and to treating employees fairly and in compliance with local laws. Our business partners must provide a safe and healthy working environment, taking into consideration any particular hazards posed by the specific operations involved. Our business partners must comply as a minimum requirement with prevailing national laws and regulations on health and safety issues. Our business partners must assure that employees are adequately trained on health and safety procedures and that necessary protective equipment is provided to and used by employees. Our business partners who provide residential facilities for their employees must comply with local laws and regulations relating to health, safety and security. 

• Wages and Benefits: Our business partners must pay wages equivalent to at least the legally mandated minimum wage.  All other benefits required by law or regulation shall also be provided, including paid holidays and vacations.  Our business partners must not make deductions for disciplinary purposes and shall provide written information to each employee specifying the wages and benefits provided for each pay period.

• Overtime Compensation: Our business partners must comply with applicable laws regarding normal working hours and compensate employees for overtime hours at such premium rate as is legally required or, if there is no legally prescribed premium rate, at a rate at least equal to the regular hourly compensation rate. Overtime shall be voluntary, must be compensated at the legally mandated rate of pay and shall be clearly documented on the written pay information provided to each employee.  

• Customs: Our business partners must share our commitment to compliance with all applicable local customs laws, and with the customs laws in the country of importation regarding the importation of the Products into the United States or other importing nation. Our business partners must respect U.S. Customs laws for importation and the laws concerning the transshipment of the Products. Transshipment is illegal and Equal Hands will not tolerate this type of transaction for purposes of country of origin rules.

• Protection and Preservation of the Environment: Our business partners must comply with applicable environmental laws and regulations.  Our business partners must have an appropriate management system in place to assure that manufacturing processes meet our commitment to progressive environmental practices and the preservation of natural resources.

• Publication and Notice: Our business partners must take appropriate steps to ensure that the provisions of this Code of Conduct are communicated to employees, including the prominent posting of a copy of this Code of Conduct, in the local language and in a place readily accessible to employees, at all times.

• Legal and Ethical Business Practices: Our business partners must comply with all applicable laws and regulations, including those pertaining to the manufacture, pricing, sale and distribution of the Products. All references to “applicable laws and regulations” in this Code of Conduct include local and national codes, rules and regulations as well as applicable treaties and voluntary industry standards. Our business partners must fully comply with all applicable local, state, federal, national and international laws, rules and regulations including, but not limited to, those relating to wages, hours, labor, health and safety, and immigration and must be ethical in their business practices.

Our business partners must allow Equal Hands the opportunity to review pertinent internal records to verify vendor’s compliance. Assuring vendor compliance includes the following key components and formal documentation of these activities:

• Annual completion of the Equal Hands’ Vendor Assessment Profile.
• Regular in-line and final inspection of all orders by Equal Hands covering observation of the compliance of these standards.
• All vendor purchase orders issued with clearly stated compliance requirements.
• Factory visits for the express purpose of identifying legal, safety and health policy compliance by a third party accreditation party, scheduled or unscheduled.

If it is found that a business partner has committed legal violations, or deals with a sub-contractor or sub-supplier, or is not in compliance with the standards set forth herein, we will take appropriate action, which may include canceling the affected purchase contracts(s), terminating our relationship with that business partner, commencing legal actions against the supplier or contractor, or any other actions as warranted. Additionally, Equal Hands may assess penalties equivalent to all damages incurred by Equal Hands to rectify non-compliance of the local and US laws already described.

Your endorsement of this letter will reconfirm our authorization to send an Equal Hands representative or agent to your premises from time to time to perform such work as is necessary to ensure that you are in compliance with our standards. You agree to cooperate fully and to provide our representative or agent with any and all information requested which is necessary to prove your compliance with the applicable laws or other matters reviewed.