NOUFŌV'S SUPPLIER WORKPLACE CODE OF CONDUCT

INTRODUCTION

The NOUFOV LLC’s (“NOUFOV”) Supplier Workplace Code of Conduct (“Code”) defines the standards for fair, safe, and healthy working conditions and environmental responsibility throughout our supply chain. 

In line with the 2030 United Nations Sustainable Development Goals, NOUFOV advocates for the responsibility of business enterprises to respect human rights which include the responsibility to avoid causing or contributing to adverse human rights impacts, to address such impacts when they occur, and to seek to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships. 

The Code’s standards are based on those of the UN Guiding Principles for business & human rights, the International Labor Organization (ILO) Core Labor Standards, the Fair Labor Association (FLA), the Ethical Trading Initiative (ETI), the World Fair Trade Organization (WFTO) and internationally accepted good labor practices. All suppliers must commit to adhering to our Code of Conduct.

Requirements in this Code apply to all factories that produce goods for NOUFOV or any of its subsidiaries, divisions, affiliates, or agents. This Code also applies to the whole supply chain, including (but not limited to) sub-suppliers, sub-contractors, and farms. Standards equally apply to permanent, temporary, and agency workers, as well as piece-rate, salaried, hourly paid, legal young workers (minors), part-time, night, and migrant workers. 

We seek suppliers committed to continuous improvement who are moving forward on their sustainability journey from basic to leadership practices. All suppliers must agree to announced and unannounced assessments by NOUFOV. NOUFOV expects all suppliers to make improvements when any of these Code standards are not met, and to develop sustainable management, reporting, and tracking systems within the factory, to ensure ongoing compliance. Timelines for achieving compliance shall be reasonable and defined. Providing proof of correction to NOUFOV for each non-compliance is also required. 

NOUFOV’s mission is to “inspire action by empowering both the wearer and the maker through creating bold, conscious, elevated products and to utilize this industry as a catalyst for positive social and environmental change.” In doing so, NOUFOV's goal is to become the most socially and environmentally progressive luxury accessory brand. 

NOUFOV seeks, at all times, to exercise the best possible practices for the respectful and ethical treatment of workers and animals and to promote sustainable conditions in which workers earn fair wages in safe and healthy workplaces. We recognize that there are different legal and cultural environments for suppliers who operate globally and we are committed to working with employers when agreed, to identify priorities for action and opportunities for improving environmental impacts, workers’ basic needs, animal welfare, and the well-being of communities.

I. LAW AND CODE COMPLIANCE

Our suppliers are expected to comply with and will be monitored to (1) all relevant and applicable laws and regulations of the country in which workers are employed including those at the federal, state/provincial, and local community levels, (2) NOUFOV’s Supplier Workplace Code of Conduct, (3) norms and best practices (4) where applicable, Collective Bargaining Agreements. 

II. NO FORCED LABOR

Employment is freely chosen. There shall be no use of forced labor, including prison, indentured, bonded, slave, or other forms of forced labor. Acts of human trafficking are also prohibited. Suppliers are required to monitor any third-party entity which assists them in recruiting or hiring employees, to ensure that people seeking employment at their facility are not compelled to work through force, deception, intimidation, coercion, or as a punishment for holding or expressing political views. In addition to being a serious violation of fundamental human rights, forced labor, slavery, slave-related practices constitute a criminal offense and/or a crime against humanity, and liability can be traced throughout the supply chain. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.  (ILO Conventions 29, 105, 182) (ETI 1.2)

III. NO CHILD LABOR

No person shall be employed under the age of 15 or under the age for completion of compulsory education, whichever is higher. Juvenile workers (ages 15-17) shall not perform work which, by its nature or the circumstances in which it is carried out, is likely to compromise their health, safety or morals. (ILO Convention 138 and 182)

IV. NO HARASSMENT, ABUSE, NOR DISCIPLINARY PRACTICES

Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological, or verbal harassment, abuse or threats, monetary fines, or embarrassing acts as a disciplinary measure or any kind of corporal punishment. 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 expressed permission of the worker concerned. (ETI 5.3)

V. NO DISCRIMINATION

No person shall be subject to any discrimination in any aspect of the employment, relationship including recruitment, hiring, compensation, benefits, work assignments, access to training, advancement, discipline, termination or retirement, on the basis of race, religious belief, color, gender, pregnancy, childbirth or related medical conditions, age, national origin, ancestry, sexual orientation, gender identification, physical or mental disability, medical condition, illness, genetic characteristics, family care, marital status, status as a veteran or qualified disabled veteran (in the USA only), caste, socio-economic situation, political opinion, union affiliation, ethnic group, illness any other classification protected under applicable law. All employment decisions must be made based on the principle of equal employment opportunity and shall include effective mechanisms to protect migrant, temporary or seasonal workers against any form of discrimination. Suppliers must ensure that women, as well as men, are able to access the resources they need to be productive, take part in decision-making in their organization and beyond, and take up leadership positions. All suppliers shall respect all legal requirements for pregnant women and new mothers.  (ILO Conventions 100 and 111) (WFTO)

VI. RESPECT FREEDOM OF ASSOCIATION & RIGHT TO COLLECTIVE BARGAINING 

Workers must be free to join organizations of their own choice. Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining and shall adopt an open attitude towards the activities of trade unions and their organizational activities. All suppliers must develop and fully implement effective grievance mechanisms which resolve internal industrial disputes, employee complaints and ensure effective, respectful, and transparent communication between employees, their representatives, and management. Workers’ representatives shall not be 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. 

(ILO Conventions 87, 98 and 135) (ETI 2.2 2.3 2.4)

VII. EMPLOYMENT RELATIONSHIP

Employers shall adopt and adhere to 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.

VIII. PROVIDE LIVING WAGE & EQUAL PAY 

We seek and favor suppliers who progressively raise employee living standards through improved wage systems, benefits, welfare programs, and other services, which exceed legal requirements and enhance the quality of life. Every worker has a right to compensation for a regular workweek that is sufficient to meet the worker’s and their family’s basic needs and provide some discretionary income. Employers shall pay wages in a timely manner, which equal or exceed minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any fringe benefits required by law and/or contract. 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. Where compensation does not meet workers’ basic needs and provide some discretionary income, each employer shall work with NOUFOV to take appropriate actions that seek to progressively realize a level of compensation that does. Employers shall respect equal pay between women and men for work of equal value and equal employment opportunities to women. (ILO Conventions 26 and 131) (ETI 5.2)

IX. PROVIDE OVERTIME WAGES

In addition to compensation for regular working hours, employees must be compensated for overtime hours at the rate legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate exceeding the regular hourly compensation rate by at least 125%. 

(ILO Convention 1 and 30)

X. NO EXCESSIVE WORK HOURS 

Suppliers shall not require workers to work more than the regular and overtime hours allowed by the law of the country where the workers are employed. The regular workweek shall not exceed 48 hours or the maximum allowed by the law of the country of manufacture, whichever is less. Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. Overtime shall be voluntary, not exceed 12 hours per week, not be demanded on a regular basis, and always be compensated at a premium rate as stated in section IX. (Provide Overtime Wages) of the Code. The sum of regular and overtime hours in a week shall not exceed 60 hours or the maximum allowed by the law of the county of manufacture, whichever is less. (ILO Convention 1)

XI. NO CORRUPTION

In respect of cultural differences and local customs, while gift-giving is acceptable to show appreciation and gratitude with no expectation of return, a gift or favor bestowed to influence the recipient’s conduct or gain benefit will be considered as a bribe and an act of corruption. Corruption is illegal and falls under national and United Nations anti-corruption regimes when applicable. NOUFOV supports and will give preference to companies with anti-corruption policies in order to prevent incidents of corruption. 

XII. PROVIDE A SAFE & HEALTHY ENVIRONMENT

Suppliers shall provide a safe and healthy workplace to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employers’ facilities. The employer shall take a proactive approach to health and safety by implementing policies, systems, and training designed to prevent accidents, injuries, minimize health risks, protect worker health, and provide security as much as possible.  Suppliers shall provide access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. Suppliers shall have an up-to-date assessment of health and safety risks in operations and shall record accidents or work-related health problems, analyzing all incidents, and taking appropriate corrective action to improve the situation. (ILO Convention 155) (ETI 3.3) (WFTO)

XIV. PROTECT THE ENVIRONMENT

Environmental damages directly threaten the right to life, to health, to water, and to develop among others. Suppliers shall comply with environmental laws and adopt credible, proactive measures to mitigate negative impacts on the environment. NOUFOV requires all suppliers to be transparent about the environmental impacts of their activities and commits to working with suppliers to identify priorities for action and opportunities for improvement. Factories shall monitor and upon request, disclose to NOUFOV, their energy and natural resource usage, emissions, discharges, carbon footprint, and disposal of wastes and take a progressive approach to minimize negative impacts on the environment. 

XV. COMMUNITY

NOUFOV encourages all 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. NOUFOV was founded with a commitment to philanthropy and supporting both environmental and social causes. We seek long-term partnerships with suppliers that share these same philanthropic values.

XVI. RESPECT ANIMAL WELFARE

Suppliers must respect animal welfare and work progressively towards adopting healthy and humane practices towards animals based on best available technology and standards. 

XVII. SAFEGUARD WORKER RIGHTS

Employers shall adopt and adhere to rules and conditions of employment that respect workers and safeguard their rights under national and international labor and social security laws. 

XVIII. NO SUBCONTRACTING

Suppliers shall be transparent about their supply chains and no subcontracting will be permitted without written approval from NOUFOV. Should subcontracting be approved, the supplier shall ensure compliance with our Code and applicable laws of any subcontractors producing NOUFOV branded or affiliate products. 

XIX. MANAGEMENT COMMITMENT

As a condition of doing business with NOUFOV, the contractor shall implement and integrate our Code and applicable laws into its business and submit to verification and monitoring. If our Code is not followed, this may result in our contracts being declared void. 

XX. TRACEABILITY

NOUFOV and our suppliers are jointly responsible for ensuring social and environmental responsibility and the integrity of our product content claims from the farm through the finished goods factory level. The only way to work towards this goal is to have transparency and traceability at all levels of our supply chain. NOUFOV requires suppliers to track and monitor all locations in all levels of their supply chain and upon request provide transparency information into the owned and/or subcontracted farms, mills, plants, factories, and other sites that are involved in the production of our products.

XXI. COMMUNICATION OF CODE & WORKER TRAINING

Suppliers commit to posting this code in a conspicuous place frequented by all employees in the local languages spoken by employees, supervisors, and managers. Suppliers also commit to training employees on their rights and obligations as defined by this Code, and applicable country laws. 

XXII. QUALITY

Quality is the result of clarity, capable and well-integrated systems, and good communication. To achieve this, factories must have a clearly documented quality system and quality improvement plan. That system must include reliable "in process" and final finished goods audits and procedures that meet NOUFOV’s quality standards. These audits must be performed by a trained staff person provided by the factory. The staff person must be granted the autonomy and support he/she needs in order to provide an unbiased report on the quality of every shipment of finished goods.