Mak Industrial Ethical Sourcing Policy

The Mak Industrial Ethical Sourcing Policy applies to all facilities that produce goods or provide services for Mak.

Mak Industrial is committed to sourcing products and services in an ethical and responsible manner, and considering the welfare of workers, health and safety and potential environmental impacts. The Mak Industrial Ethical Sourcing Policy is based primarily on Ethical Trade Initiative Base Code (ETI), conducting business ethically, manufacturing responsibly and demonstrating environmental consciousness. The policy details the minimum requirements that suppliers must meet in order to conduct business with Mak Industrial.

1. Policy requirements

• All suppliers are required to agree to the principles in the Mak Industrial Ethical Sourcing Policy and as set out in their Trading Agreement with Mak Industrial.

• If suppliers are unable to demonstrate a commitment to comply with the Mak Industrial Ethical Sourcing Policy, Mak Industrial reserves the right to terminate the Trading Agreement, and all current purchase orders.

• Suppliers must complete a self-assessment (Mak Industrial Ethical Sourcing Self-Assessment Questionnaire) and Mak Industrial may, at its discretion, require an independent audit of a supplier’s compliance with this policy.

• Mak Industrial will also mutually recognise the below current (no older than 12 months or if currently undergoing an audit) Ethical Sourcing (ES) audits in lieu of an independent audit of a supplier’s compliance to this Policy: Supplier Ethical Data Exchange (Sedex).

2. Legal requirements

• All suppliers must fully comply with all local laws and regulations regarding labour, health, safety and the environment. Suppliers must also fully comply with the legal requirements of the countries in which they operate in addition to all elements of this Ethical Sourcing Policy.

3. Child labour shall not be used

• Suppliers must not use child labour. Child labour is defined as work that deprives children of their childhood, the opportunity to attend school and fulfil their potential and that is harmful to their physical, moral and mental development.

Suppliers must be able to verify the age of all employees to ensure no child labour is used. All suppliers shall comply with the minimum legal working age in the country in question orby the ETI clause 4, whichever is higher.

• Suppliers must develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child and must implement effective systems to prevent the use of child labour in the future.

• Children and young persons under the age of 18 must not engage in hazardous work.

4. Employment is freely chosen and forced labour shall not be used

• Suppliers must not engage in forced, bonded or involuntary labour.

• Suppliers will ensure that employment is freely chosen, workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

5. No harsh nor inhumane treatment is allowed

• Workers’ shall be treated with dignity and respect. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation are prohibited

6. Discrimination

• There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

7. Freedom of association and the right to collective bargaining are respected

• Suppliers acknowledge that workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

• Suppliers are required to adopt an open attitude towards the activities of trade unions and their organisational activities.

• Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.

• Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

8. Working conditions are safe and hygienic

• Suppliers must ensure that a safe and hygienic working environment is provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

• Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

• Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

• The company observing the code shall assign responsibility for health and safety to a senior management representative.

9. Wages and benefits

• Suppliers must ensure that wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher.

• All workers shall be provided with written and understandable Information about their employment conditions in respect to wages before they enter employment, and about the particulars of their wages for the pay period concerned, each time that they are paid.

• Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the express permission of the worker concerned. All disciplinary measures should be recorded.

• Overtime will be remunerated at a premium rate if legally required or, at a minimum, regular hourly compensation.

10. Working hours are not excessive (based on ETI)

• Including any overtime, workers must not work above the maximum hours per week or per month as stipulated by local laws, or where local laws do not exist, a total of 60 hours in any 7 day period, as per ETI clause 6.5.

• Workers must have at least one day off in 7 days or two days off in every 14 days.

• Overtime must be voluntary, not be excessive or demanded on a regular basis and must be compensated as prescribed by local laws.

11. Regular employment is provided

• To every extent possible work performed must be on the basis of a recognised employment relationship established through national law and practice.

• Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

12. Environment

• Suppliers must comply with local and national environmental laws and regulations, ensuring no impact on the health of the local environment and community.

Suppliers must use reasonable endeavours to comply with international standards on environmental protection and have programs for continual improvement.

• Suppliers must ensure safe disposal of waste and safe use of and disposal of chemicals, and maximise recycling.

13. Sub-contracting and supply chain

• There must be no sub-contracting unless previously approved by Mak Industrial. Such arrangements must be documented and available for review by Mak Industrial or an independent auditor, including but not limited to records of subcontractor’s names and locations. Mak Industrial considers sub-contracting to mean: o Sites contracted by Mak Industrial’s direct suppliers to produce products in its final form o Sites that significantly contribute to the final form of the product o Sites that apply branding to product o Service providers contracted by Mak Industrial’s direct service provider to deliver any service in substitution of the direct provider

• Suppliers must have adequate policies and procedures in place for properly managing subcontracting to ensure that sub-contractors operate in accordance with applicable laws, regulations and the Mak Industrial Ethical Sourcing Policy.

14. Business integrity

• Suppliers must engage professional business ethics in all dealings.

• Bribes, favours, benefits or other similar unlawful or improper payments, in cash or in-kind, are strictly prohibited, whether given to obtain business or otherwise.

• Suppliers must notify Mak Industrial via email immediately should any form of conflict of interest become apparent.

15. Management system, documentation and policies

• Appropriate documentation and evidence must be in place to ensure effective ethical management practices.

• Appropriate policies must be developed to ensure effective management of ethical issues.

• Without prejudice to paragraph 1, where non-compliances to this policy are identified, these must be remedied within appropriate timeframes and verified by Mak Industrial to ensure appropriate actions have been taken.