Norwood Social Responsibility Standards

Norwood believes that all employees deserve to be treated with dignity and respect. In every aspect of the employment relationship, employers should treat their employees as they would themselves want to be treated. Norwood strongly believes that those manufacturers and their subcontractors approved to do business with Norwood should follow this philosophy. Norwood will not do business with those who do not uphold, in action as well as words, the same principles.

Norwood recognizes that its manufacturers and their subcontractors are independent businesses. Nonetheless, actions by those with whom Norwood does business are sometimes attributed to Norwood which affects its reputation and goodwill. As a consequence, Norwood expects its manufacturers and their subcontractors to act with a high level of honesty and integrity. For these reasons, Norwood has established the following "Code of Conduct".All manufacturers doing business with Norwood must comply with this Code of Conduct. Manufacturers must also ensure that their subcontractors who work on Norwood products also comply with this Code of Conduct. All references to manufacturers in the Code of Conduct below shall also include all applicable subcontractors.

Failure to comply with this Code of Conduct will be sufficient cause for Norwood to terminate its business relationship with the violating manufacturer and will also be sufficient cause for Norwood to revoke a violating subcontractor's approved status. Norwood will conduct (or have its agent conduct) periodic inspections of its manufacturers' and their subcontractors' facilities to verify compliance with Norwood standards.

CODE OF CONDUCT

1. Obligation to Comply with Applicable Laws, Regulations and Standards. All business activities of Norwood's manufacturers shall comply with and conform to all applicable international, national (including the USA and other countries with jurisdiction), state, provincial, and local Laws, rules, regulations, governmental orders and directives, customs, and industry standards pertaining to product safety, employment and manufacturing (collectively,"Laws").

2. Employment Practices.


a. Prison or Forced Labor. The use of prison or forced labor by a manufacturer is absolutely forbidden. Likewise, the use of labor under any form of indentured servitude is absolutely forbidden, as is the use of physical punishment, confinement, threats of violence or other forms of physical, sexual, psychological or verbal harassment or abuse as a method of discipline or control. Manufacturers shall not knowingly utilize factories or production facilities that force work to be performed by unpaid or indentured laborers or those who must otherwise work against their will.
b. Child Labor. The use of child labor by manufacturers is strictly prohibited. Manufacturers are absolutely forbidden from using workers under the legal age of employment for the type of work in the country where the manufacturer produces products for Norwood. If the country in which the manufacturer is doing business does not define "child" for purposes of minimum age of employment, the minimum age of employment shall be 15 years of age, and the employment of any individual to manufacture or produce products for Norwood below that age is absolutely forbidden. Children 15 and 16 years of age may only be permitted to work during periods of time when they are not required by Laws to attend school (except as may be permitted under apprenticeship or other similar programs in which the minor is lawfully participating).

c. Working Hours. Manufacturers must ensure that all of their employees, laborers, agents, contractors working on products manufactured for or supplied to Norwood do so in compliance with all applicable Laws and in accordance with published industry standards pertaining to the number of hours and days worked. Such employees, laborers, agents and contractors are to be provided with reasonable daily and weekly work schedules and adequate allowance is to be made for time off. Except in extraordinary business circumstances, employees, laborers, agents and contractors will not be required to work more than either: (a) the limits on regular and overtime hours allowed by local Laws; or (b) 60 hours per week, inclusive of overtime. Adequate time off shall be at least one day off per week, except in extraordinary business circumstances. In the event of a conflict between an applicable Law and a published industry standard pertaining to work hours, compliance must be made with the one taking precedence under national Law.
d. Compensation. A manufacturer's employees, laborers, agents and contractors working on products manufactured for or supplied to Norwood must be fairly compensated and provided with wages and benefits that comply with applicable Laws. If local Laws do not provide for overtime pay, manufacturers and their subcontractors will pay at least regular wages for overtime work.
e. Non-Discrimination. Manufacturers shall implement a policy that conforms to applicable Laws prohibiting discrimination in hiring and employment practices on the grounds of race, color, religion, sex, age, physical ability, national origin, or any other prohibited bases.
f. Workplace Environment. Manufacturers shall provide their employees, laborers, agents and their subcontractors with safe and healthy working and, where provided, living conditions. At a minimum, potable drinking water, adequate, clean restrooms, adequate ventilation, fire exits and essential safety equipment, an emergency aid kit, access to emergency medical care, and appropriately-lit work stations must be provided. In addition, facilities must be constructed and maintained in accordance with the standards set by applicable Laws.

3. Inspections. Norwood reserves the right to conduct or have its agent inspect manufacturer's workplace environment, employment practices, business practices, records, facilities, and, if provided by a manufacturer, housing accommodations, as well as conduct private interviews with employees. Manufacturers shall keep all information necessary to document compliance with this Code of Conduct readily available to Norwood for inspection and copying. Failure to permit Norwood to allow such inspections and interviews shall be sufficient cause for Norwood to terminate its business relationship with a manufacturer and will also be sufficient cause for Norwood to revoke a subcontractor's approved status.

4. Compliance Inspection Report. Manufacturers must receive "passing" compliance inspection reports from Norwood. A "passing" compliance inspection report means an inspection report clearly stating that a manufacturer is in compliance with this Code of Conduct and other Norwood standards in all material respects.