BUCK WEAR, INC. SOCIAL COMPLIANCE POLICY

Our Social Compliance Policy aims to improve both our social and environmental impact in the communities that we do business with throughout the world. Our policy applies to all facilities that produce goods for Buck Wear, Inc., or any of its subsidiaries, divisions, or affiliates.

While Buck Wear, Inc. recognizes that there are different legal and cultural environments in which factories operate throughout the world, the Buck Wear, Inc. Social Compliance Policy sets forth the basic requirements all factories must meet in order to do business with Buck Wear. Accordingly, it is the responsibility of all Buck Wear business partners, suppliers, agents, and designated third parties to act in accordance with the Buck Wear Code of Conduct.

Buck Wear strongly encourages contractors, agents, and suppliers to exceed the Code of Conduct requirements and to promote best practices and continuous improvement throughout all of their factories.

The Buck Wear Code of Conduct must be posted in all major workplaces, translated into the language(s) of the employees.

Our goal is to use the Code of Conduct and audit results as an integral part of our supply chain strategy, influencing how we rate, select and build vendor partnerships now and in the future.

CODE OF CONDUCT SOCIAL COMPLIANCE AUDIT POLICY

It is Buck Wear’s policy to monitor every facility that is involved in the manufacture of a Buck Wear branded product, and brands for which Buck Wear is licensed to produce. This includes all finished goods factories. Audits will also eventually encompass cutting facilities, sewing plants, screen printers, embroiderers, laundries, packaging locations, and raw material suppliers.

Absolutely no production can be performed in a new facility until a factory inspection has taken place. Production includes samples that are regularly produced at the same location as well as bulk orders. Violation of this policy can result in the termination of any existing contracts or licensing agreements.

These assessments are designed to ensure that, at a minimum, all facilities manufacturing our products comply with our strict Code of Conduct, local and international laws, and the codes which we adhere to, including those set forth by the Worldwide Responsible Accredited Production (WRAP) and the Fair Labor Association (FLA). All the aforementioned codes and standards include strict provisions with regards to forced and child labour such as human trafficking and slavery. When external suppliers are used, they must also adhere to these codes. This is a requirement for conducting business with Buck Wear, Inc.

Factory inspections will be conducted by a Buck Wear Compliance Auditor or by an accredited third party audit company. The facility manager and any associated agent may or may not be notified prior to the inspection.

Audits will be conducted regularly on every factory. The first audit will be paid for and scheduled by Buck Wear and all subsequent audits will be the responsibility of the factory, including an annual audit prior to sample or bulk production.

Each inspection will include a thorough audit of the facility for Health and Safety, Social Compliance, Forced Labor and Human Trafficking, and Environmental issues. Factory records involving payroll, operating licenses, employee personnel records, etc. will be reviewed for legal compliance with local laws. Plus, a random sampling of employees will be interviewed to evaluate working conditions at the facility.

Non-compliance with Buck Wear’s Code of Conduct can result in corrective action or even termination of a commercial agreement, depending on the number of non-compliances found as well as their severity. Buck Wear will always first seek a viable remediation strategy with suppliers found not in compliance with our Code of Conduct. However, we may terminate a business relationship with a contractor if deemed necessary. Our team works with contractors to develop action plans to resolve any instances of noncompliance.

MIGRANT LABOR POLICY

  • All employment contracts and other work related information must be truthful, clearly written and provided in the worker’s native language.
  • Workers must be provided with contracts and wages that equal or exceed those of local workers per the policy, and must be treated equally in the workplace.
  • Workers should not pay any recruitment fees or other related employment fees from country of employment or home country – including transportation to and from the host country per the policy.
  • Workers shall retain possession and control of their personal identity documents, such as passports, identity papers, travel documents, and other personal legal documents at all times.
  • Health insurance and Labor insurance fees will be paid based on the law by both the worker and the factory. Workers will benefit from the paid insurance in the situation of death, accident, injury, disability etc.

ETHICAL RECRUITMENT POLICY

Local agency fees may only be allowed if the fees are specifically allowed by local law and so long as they do not exceed a combined total of 1 month’s salary on an annual basis. If the fees charged exceed the local law or exceed the 1-month salary requirement, the supplier will be required to repay the fees charged to the worker.

FREEDOM OF ASSOCIATION POLICY

Our business partners are required to recognize and respect the right of their employees to freedom of association and collective bargaining. Employees should be free to join organizations of their choice. Employees should not be subjected to intimidation or harassment in the exercise of their right to join or to refrain from joining any organization.

AUDIT DECEPTION POLICY

Buck Wear prohibits any factory from offering, promising or giving any money, gifts, meals (other than in the factory canteen), accommodations, entertainment or anything else of value to any Third Party Assessor. If Buck Wear determines that a factory provided any of the above to an associate or Third Party Assessor in order to inappropriately influence their actions, Buck Wear will likely terminate the Company’s relationship with that factory. If a Buck Wear associate or Third Party Assessor requests anything of value from a factory, the factory should report these request to dtrapp@buckwear.com immediately. Similarly, if an authorized Third Party Assessor is accused of soliciting or accepting a bribe, they and their employer can have their Buck Wear accreditation revoked. All authorized Third Party Assessors are held to an unconditional Code of professional conduct which means they cannot, directly or indirectly, seek or accept monetary “kickbacks” or any other benefit (e.g. gifts, free products, favors, promises of future worker) in connection with an assessment or any related follow-up work.