KEY CODE ISSUES

• CHILD LABOR
Kellwood Code:
The use of child labor is not permissible.
Kellwood Expectations:
Kellwood defines "illegal" child labor as follows:
a. under the legal age within host country.
b. under the compulsory age to be in school in host country.
c. under the age of 14 regardless of host country law.

Kellwood also expects facility to meet all host country requirements pertaining to documentation and job placement of restricted age workers. Kellwood further expects on-site facility contractors (canteen, trimming services, etc.) to comply with laws pertaining to child labor.

• WAGES AND BENEFITS
Kellwood Code:
The wage structure and benefits of our business partners must comply with applicable laws.
Kellwood Expectations:
Kellwood expects that factories comply with applicable wage/benefit laws of host country. This includes:
a. pay at least minimum wage for all employees, including piece workers, for all hours worked.
b. hours worked in excess of host country standard must be paid at legal overtime premium.
c. pay frequency in accordance with host country law.

• WORK HOURS
Kellwood Code:
The work hours of our business partners must comply with applicable laws.
Kellwood Expectations:
Any hours worked over the legal standard must be paid at the prescribed overtime rate and be worked voluntarily. We also expect workers will be provided time off from their duties to rest and be with their families. Kellwood expects factory to operate according to host country laws pertaining to work hours. If exemptions are allowed by law, factory must have official documentation approving exemption. Overtime must be voluntary, meaning employees must agree to hours they work, within legal limits, to meet production schedules. The work hours should be reviewed with employees and signed employee acceptance should be on file. If host country has allowed 7th day rest law, any 7th day work hours must be voluntary and within legal maximum hours allowed. Kellwood expects factory to have systematic time records to establish employee work hours and expects all work performed to be time recorded.

• PRISON OR FORCED LABOR
Kellwood Code:
We will not knowingly utilize or purchase materials and/or product manufactured by prison or forced labor.
Kellwood Expectations:
Kellwood prohibits prison, forced, indentured or bonded labor. There should be no restriction on free movement of employees:
a. to work in another factory.
b. to leave premises of current factory if necessary.

There should be no withholding of ID papers, involuntary employee "deposits", or other practices that would be restrictive to workers.

• HUMAN RIGHTS: DISCIPLINARY PRACTICES
Kellwood Code:
We will not condone any type of harsh disciplinary practices by business partners.
Kellwood Expectations:
Kellwood prohibits harassment, abuse, corporal, mental or physical punishment of employees. Kellwood views regular yelling at workers as a form of verbal abuse. Kellwood does not allow monetary deductions as a disciplinary practice.

• HUMAN RIGHTS: FREEDOM OF ASSOCIATION
Kellwood Code:
We recognize the right of employees to exercise their legal rights of free association.
Kellwood Expectations:
Kellwood supports employee's ability to exercise their legal rights of free association. The posted Kellwood Code of Conduct states our position and contractor factories must agree with this position.

• HUMAN RIGHTS: DISCRIMINATION
Kellwood Code:
We believe people should be employed based on their ability to perform a needed function; not on the basis of personal characteristics or beliefs.
Kellwood Expectations:
Kellwood views mandatory pregnancy testing as a human rights violation even if not restricted by host country law. Kellwood's position is that pregnancy testing is not allowed as
a. a reason to not hire, or
b. a reason to terminate employment.

Other forms of discrimination are also prohibited.

• HEALTH AND SAFETY
Kellwood Code:
We expect our business partners to provide a safe and healthy work place for their employees. If living facilities are provided, we expect the same level of safety and health as in the work place.
Kellwood Expectations:
Kellwood expects the factory to meet all host country laws pertaining to factory and dormitory (if applicable). In absence of or in addition to specific country standards, Kellwood expects factories to have:
a. adequate first aid supplies available.
b. exits clearly marked, unlocked and unblocked.
c. at least two exits per floor.
d. main exit doors allow clearance of building.
e. illustrated evacauation plan in native language.
f. accessible and functional fire extinguishers or hoses on each floor, with valid inspection dates.
g. facility clean, free of insect/rodent infestation.
h. unresticted access to potable water.
i. restrooms clean and functional.
j. adequate ventilation.
k. no obvious fire hazards (exposed wiring, overloaded outlets, improper storage of combustible materials, etc.)

Kellwood also expects for canteen areas:
a. two ways to exit.
b. fire fighting equipment.
c. proper trash containment.
d. potable water.
e. free of insect/rodent infestation.
f. no hazardous chemical storage.

Kellwood also expects for dormitory:
a. overall dormitory clean and safe.
b. sleeping quarters segregated by gender,clean and safe.
c. number of occupants in dorm room not exceed legal capacity.
d. unrestricted access to potable water.
e. restrooms/showers clean and functional.
f. adequate ventilation and lighting in rooms.
g. at least two exits per floor.
h. exits clearly marked, unlocked and unblocked.
i. no hazardous or combustible materials kept in dorm.
j. illustrated evacuation plan in native language.
k. at least two functional fire extinguishers on each floor.

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