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2022 Supplier Code of Conduct
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Supplier Code of Conduct

This Code of Conduct – or “CoC”- describes the minimum standards of business conduct which we

see as fundamental in our dealings with suppliers. We expect all our business partners – from

the component sourcing through to the final production process – to fully comply with the

following standards. Just as we do ourselves.

We consider ourselves responsible for all of the activities carried out in our name worldwide. We feel

a particular responsibility to provide decent working conditions for the employees producing our

products. This responsibility involves all employees who make products or part of products for

The Landmark Project regardless of whether they are directly employed by The Landmark Project or by third party subcontractors and suppliers.

We work in compliance with national and international applicable laws and regulations.

Moreover we have set social and environmental criteria based on the conventions of the

International Labor Organization (ILO) and UN Conventions. We ask our suppliers to support us in

Complying with the standards set below.

Whenever it is clear that a supplier does not act in accordance with the requirements set

out in this CoC, we may consider to end our business relationship with this supplier

(including the cancellation of any outstanding orders) if the supplier does not take the

necessary corrective action in order to ensure compliance with the CoC.

1. Legal Compliance

1.1 Law

All our employees and business partners will follow the national and international laws and

regulations that apply to the business that is conducted. When these law conflict with the CoC,

suppliers must choose that side which provides the greater protection of workers or the

environment.

1.2 Intellectual Property Rights

Suppliers must ensure that intellectual property rights are respected, and that unlawful copies are

neither offered, nor produced.

2. Management Systems

Suppliers are expected to implement management systems which comply with all applicable laws

and promote improvement with respect to the expectations of this CoC. This includes the following

aspects:

● Legal and Other Requirements: suppliers will comply with all laws, regulations, contractual

agreements and generally recognized standards.

● Communication of Sustainability Criteria in Supply Chain: the supplier will communicate the

principles of this CoC to their supply chain.

● Commitment and Accountability: suppliers are encouraged to fulfill the expectations of this

Supplier CoC by using the right resources.

● Risk Management: suppliers are expected to implement mechanisms to identify, determine and

manage risks in all areas addressed by this CoC and with respect to all legal requirements.

● Documentation: suppliers are expected to develop correct documentation to demonstrate that they share the principles and values expressed in this CoC. This documentation may be reviewed by

The Landmark Project upon mutual agreement.

● Training and Competency: suppliers will establish training measures for their managers and

employees to gain a good level of knowledge and understanding of the contents of this CoC, the laws

and regulations and generally recognized standards.

● Continuous Improvement: suppliers are expected to continuously improve their sustainability

performance by implementing the necessary measures.

● Audits: Audits should take place on a semi-announced basis by default, which means the supplier is aware an audit will take place but is not notified of the date. Only first audits are allowed on a fully-announced basis. Suppliers agree to be audited by an accredited auditing firm on behalf of The Landmark Project or by our partners in order to monitor their social compliance progress rate.

3. Labor

3.1 Child Labour

ILO Conventions 10, 79,138,142 and 182 and Recommendation 146 and CRC, art. 32(1)

The use of child labour will not be tolerated. The age for admission to employment shall not be less

than the age of completion of compulsory schooling and, in any case, not less than 16 years. There

shall be no forms of slavery or practices similar to slavery, such as the sale and trafficking of children,

debt bondage and serfdom and forced or compulsory labor. Children in the age of 16-18 shall not

be engaged in work which, by its nature or the circumstances in which it is carried out, is likely to

harm their health, safety (including night work), morals, or education.

3.2 Discrimination

ILO Conventions 100, 111, 143, 158, 159, 169 and 183.

No discrimination shall be tolerated in hiring, remuneration, access to training, promotion,

termination or retirement based on gender, age, religion, race, social background,

disability, ethnic origin, nationality, political affiliation or opinions, sexual orientation, family responsibilities, marital status, or any other condition that could give rise to discrimination.

3.3 Forced and Compulsory Labor and Disciplinary Measures

ILO Conventions 29 and 105

There shall be no use of forced, bonded (including debt bondage) or involuntary prison labor,

slavery or trafficking of people in any form. All forms of forced labor, such as lodging deposits or the

retention of identity documents from personnel upon commencing employment, are forbidden as is

prisoner labor that violates basic human rights. Workers shall be free to vacate the workplace

premises at the end of the workday. All workers are entitled to a written contract of employment in a

language they understand.

3.4 Freedom of Association

ILO Conventions 11, 87, 98, 135 and 154

The right of all workers to form and join trade unions and bargain collectively shall be recognised.

The company shall, in those situations in which the right to freedom of association and collective

bargaining are restricted under law, facilitate parallel means of independent and free association and

bargaining for all workers. Workers' representatives shall not be the subject of discrimination and

shall have access to all workplaces necessary to carry out their representation functions.

3.5 Harassment, Abuse and Disciplinary Actions

Suppliers must treat workers with dignity and respect, and not engage in or tolerate bullying,

harassment, intimidation, violence, corporal punishment, physical and/or mental abuse or other

forms of coercion. Suppliers must have a written policy or plan to address violation(s) and provide a

confidential procedure for employees to report harassment, corporal punishment, physical and/or

mental abuse. This procedure must be secure and should not scrutinize employees. Management

and supervisors should be encouraged to take classes that provide training on harassment,

awareness, sensitivity to other cultures, corporal punishment, and mental abuse.

3.6 Protecting the Vulnerable

Suppliers must give special consideration to the rights of those most vulnerable to abusive labor

practices, such as women, home workers, agency workers, temporary workers, and migrant workers.

3.7 Employment Relationship

Suppliers must engage with workers on the basis of rules and conditions of employment that respect

workers and, at a minimum safeguard their rights under national and international labor and social

security laws and regulations.

3.8 Workplace Health and Safety

ILO Convention 155

A safe and hygienic working environment shall be provided, and best occupational health and safety

practice shall be promoted, bearing in mind the prevailing knowledge of the industry and of any

specific hazards. Appropriate attention shall be paid to occupational hazards specific to this branch of

the industry and assure that a safe and hygienic work environment is provided for. Effective

regulations shall be implemented to prevent accidents and minimize health risks as much as possible.

Personal protection Equipment (PPE) should be provided free of charge to workers where needed. All

medical equipment (such as first aid kits, etc.) shall be available in sufficient numbers throughout the

factory, maintained and stocked as prescribed and easily accessible to workers. A sufficient number

of workers shall be trained in first aid. Occupational health checks should be conducted on a regular

basis by a qualified nurse or doctor; the record of these checks should be kept in good order. Free potable water should be reasonably accessible to all workers throughout the working day. Workers should have access to reasonably clean and private toilet facilities in adequate numbers.

3.9 Building Fire and Safety

ILO Convention 155 and ILO Recommendation 164

The factory must be able to display, with relevant permits, that production buildings and installations

in such buildings, are of the correct standard for how they are being utilized. There shall be an

automatic fire alarm system. Fire drills and testing of emergency systems shall be conducted on a

regular basis. All safety equipment (such as firefighting equipment etc.) shall be available in

sufficient numbers throughout the factory, maintained and stocked as prescribed and easily

accessible to workers. A sufficient number of workers shall be trained in firefighting techniques.

Buildings shall be provided with a clear and unobstructed way of exit for all occupants to safely

evacuate, that includes (but is not limited to) a sufficient number of clearly marked, unlocked and

unblocked exits, and safe and unobstructed exit pathways leading out of the premises. Evacuation

plans shall be in place and shall be posted at the entrance to each exit stair. Electrical systems, panels

and wiring must be installed by certified electrician, shall be properly documented, and must be

maintained in good working order. The generator and boiler must be kept separately from the

production area. There shall be proper ventilation, windows, fans, air conditioning and /or heating in

at workplaces, so that circulation, ventilation and temperature requirements are met. The factory

shall ensure that the noise level is acceptable. The lighting must be sufficient to ensure a safe

working environment. If the factory provides food for its workers, the canteen, in which food is

stored and prepared, must be located separately from the production area and also be clean and in a

good condition.

3.10 Wages & Benefits

ILO Conventions 12, 26, 101, 102 and 131

Employers shall provide all legally mandated holidays, leave, benefits and bonuses, such as official

holidays, annual leave, sick leave, maternity leave, severance payments and 13th month payments,

to all eligible workers within legally defined time periods. In addition, all leave and bonuses shall be

calculated correctly. Illegal, unauthorized or disciplinary deductions from wages shall not be made.

Deductions from wages as a disciplinary measure are forbidden, unless this is permitted by national

law and a freely negotiated collective bargaining agreement is in force. All employees should be

made aware of their payment conditions before they commence their employment and receive a

copy of their labor contract. Employees shall not ask their workers for a deposit or withhold wages of workers; minimum wage does not include wage compensation for overtime work or allowances.

3.11 Working Hours

ILO Conventions 1 and 14 and ILO Recommendation 116.

Hours of work shall comply with laws and industry standards. In any event, workers shall

not on a regular basis be required to work more than 48 hours per week and shall be provided with

at least one day off for every seven-day period. Overtime shall be voluntary, shall not exceed 12

hours per week, shall not be demanded on a regular basis and shall always be compensated at a

premium rate.

3.12 Subcontracting

The Landmark Project does not permit subcontracting without our prior written approval. All

salesman-sample and bulk production orders must be placed within facilities that have been pre approved by The Landmark Project, without exception. Direct suppliers are required to continuously

monitor approved subcontractors and sub-suppliers for social and environmental responsibility using

standards that meet or exceed our Code of Conduct.

3.13 Traceability

We require our suppliers to map and continuously track and monitor all locations in all levels of their

supply chain and upon request provide transparency information into the farms, mills, plants,

factories and other sites that are involved in the production of our products.

3.14 Product Safety and Quality

The supplier must meet generally recognized or contractually agreed quality requirements and

comply with safety standards and all legal and labeling requirements and specifications. Factories

must have a clearly documented quality system and quality improvement plan. This system must

include reliable "in process" and final finished goods checks. These checks must be performed by

qualified parties. Finally, if requested, our QC staff members must be given the autonomy and

support he/she needs to provide a neutral check and report on the quality of a selected shipment of

finished goods.

3.15 Community

We encourage our suppliers and their employees to get involved in local social and environmental

community charity efforts by volunteering time and/or providing other types of support.

4. Environment and Animal Welfare

Suppliers must assure environmental protection in all their activity and comply with all

environmental laws. They must also respect animal welfare and work progressively towards adopting

healthy and humane practices towards animals based on best available technology and standards.

Reasonable efforts must be taken to ensure that purchasing decisions do not contribute to

deforestation, cruel treatment of animals, or adverse impacts on vulnerable ecosystems or

endangered species.

4.1 Environment and Safety Compliance

Suppliers must have an environmental management system in place and integrate environmental

impact into business decisions. They should take a proactive approach towards improving

environmental performance, and require the same from their suppliers and subcontractors.

Procedures and standards for waste management, handling and disposal of chemicals and other

dangerous materials, emissions and effluent treatment must comply with or exceed environmental

laws. Suppliers must assure environmental protection in all their activity and agree to be monitored

separately for environmental responsibility if necessary. This includes production procedures, waste

management, handling and disposal of dangerous material – such as chemicals – and emissions.

4.2 Resource Use, Emissions and Pollution

Suppliers must take measures to continuously improve energy efficiency in buildings, transport &

production, and make reasonable efforts to use renewable or less carbon intensive energy sources.

Factories shall continuously monitor, and, if requested, disclose to The Landmark Project their energy

and natural resource usage, emissions, discharges, carbon footprint and disposal of wastes and take

a proactive approach to minimize negative impacts on the environment. Suppliers must take

measures to minimize noise pollution and emissions to air, soil, and groundwater.

4.3 Waste Water

Suppliers with wet processes (including dyeing and finishing/washing plants) must take measures to

continuously improve water efficiency and facilitate reuse & recycling where possible. Suppliers must

treat wastewater properly prior to discharge, test the wastewater as required to meet all national

and local water discharge compliance standards, and share wastewater quality data with

stakeholders, upon request from The Landmark Project.

4.4 Hazardous Chemicals

Suppliers using chemicals must meet the standards set out in our MRSL and work with The Landmark Project and their own suppliers towards the elimination of hazardous substances from the supply

chain.

4.5 Protecting Animal Life

The Landmark Project does not allow the use of genuine fur, skins, leather, or feathers in the manufacturing of its products. All products sold to are to be produced without causing harm to animals. No products in full or part are to be sourced from endangered species listed by the Convention on International Trade in Endangered Species (CITES) or International Union for the Conservation of Nature (IUCN). Wool cannot be sourced from producers that use mulesing as part of their animal husbandry strategies.

5. Anti-corruption

Suppliers must comply with all applicable anti-bribery and corruption laws. Suppliers must not offer,

pay, solicit or accept bribes, including facilitation payments. Suppliers must have an anti-corruption

policy and procedures in place, and review them regularly to ensure that they are operating

effectively.

6. MONITORING and ENFORCEMENT

6.1 Transparency and Co-operation

We expect all our business partners to fully comply with this CoC. We also expect our suppliers and

other business partners to be transparent and not intentionally mislead our official auditor bodies.

We believe in co-operation and we are willing to work with our suppliers and other business partners

to achieve sustainable solutions and to promote suppliers and other business partners who are in

compliance. Ethical behavior is required and any breaches of The Landmark Project CoC must

immediately be reported to local management or to The Landmark Project leadership (Matthew Moreau;

matt.moreau@thelandmarkproject.com).

6.2 Monitoring

Relevant documentation must be maintained for auditing purposes. We have the right to make

unannounced visits to all units producing goods or services for The Landmark Project at any time. We

also reserve the right to appoint an independent third party of our choice to conduct audits in order

to evaluate compliance with our CoC. During audits we require access to all areas of the premises, to

all documents and to all employees for interviews. We also demand the right to provide employees

with contact details for The Landmark Project.

6.3 Supply Chain

The Landmark Project CoC applies to our direct suppliers, other business partners and

manufacturers of goods or services for The Landmark Project.

6.4 Corrective Action

Our audits aim to identify gaps between the requirements in this CoC and the actual practices and

conditions in the workplace. The audited company will usually be given the opportunity to propose

and implement a corrective action plan (CAP). We will follow up the implementation of the plan and check

whether all CAPs have been remediated. A supplier failing to undertake these improvements within the indicated time frame would seriously damage its relationship with The Landmark Project.

Unwillingness to cooperate or repeated serious violations of the The Landmark Project CoC and local

law may lead to reduced business and ultimately termination of the business relationship with us.

Acknowledgement

I hereby declare that I have received a copy of The Landmark Project Code of Conduct (the "CoC") and

understand and agree to its contents.

Company name (typed or printed)

Authorized company representative’s name and title Date