Supplier Code of Conduct

The Earth Group is committed to conducting and managing our business in a manner that reflects our high ethical and moral values. We expect our suppliers to respect and adhere to the same philosophy in the operation and management of their businesses.

As part of this commitment, The Earth Group has developed this Supplier Code of Conduct (“Code”), which establishes standards for all of its suppliers. In addition to complying with local laws and regulations, The Earth Group requires suppliers to be honest, transparent and committed to making continuous improvements against these standards. For the purposes of the Code, a supplier is any manufacturer or subcontractor engaged a manufacturing products meant for resell by The Earth Group.

This Code is to be strictly adhered to whenever a potential new supplier is considered or entered into negotiation with. The Earth Group will monitor compliance with this Code, and we, or our representatives, may visit suppliers and their subcontractors to ensure compliance with this policy. Any violations of our Code will be reported to the supplier for follow up and corrective action. Suppliers are required to cooperate with the entire process. Where there are Zero Tolerance violations and/or the supplier does not demonstrate a willingness to comply, The Earth Group reserves the right to discontinue business with the supplier.

1. Legal Compliance

Suppliers are expected to operate in compliance with all applicable laws and regulations of the regions in which they operate. This includes laws and regulations related to ethical business practices, quality, labour and employment practices, as well as health, safety and environmental protection. Suppliers are also expected to conform their practices to generally accepted industry standards, obtain and maintain all applicable permits, licenses and registrations, and operate in accordance with permit limitations and requirements at all times.

2. Labour and Human Resources

Suppliers are expected to comply with all local country labour and human resource laws and regulations, including those related to wages, hours worked, working conditions and child labour. Suppliers are also expected to adopt sound labour and human resource practices and treat their workers fairly. Suppliers must hire and employ workers in compliance with applicable laws. Wages, benefits, and working hours are expected to be fair and reasonable in the local labour market. All work shall be voluntary. Except in extraordinary business circumstances, workers shall not be required to work (inclusive of overtime) more than the legally prescribed limits or 40 hours, whichever is less, and two days off in every seven day period shall be provided.

Rest periods for breaks and meals are provided. At least 10 paid days of vacation are provided per year. Suppliers must comply with the applicable local laws with regard to the minimum hiring age for employees. Suppliers are not to use labour that is a result of mental or physical coercion, physical punishment, slavery or other oppressive labour conditions. Suppliers and their employees cannot engage in any form of human trafficking. Suppliers must respect workers’ right to associate freely, in compliance with existing local laws and without intimidation, reprisal or harassment. Workers shall be treated with dignity and respect. In particular, suppliers will not permit physical, sexual, psychological or others forms of mental or physical coercion, harassment, abuse or intimidation. Further, the use of fines as a disciplinary practice is not permitted.

3. Discrimination

Discrimination in employment, including hiring, pay, benefits, job assignments, working conditions, training, recruitment, promotion, discipline, termination, and retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion and social or ethnic origin is prohibited. Workers should be provided with an environment where they can work without distress or interference caused by harassment, discrimination or any other inappropriate workplace behaviour.

4. Environmental Practices

Suppliers, at a minimum, will meet all relevant local and national environmental protection laws and regulations, and will strive to comply with international environment protection standards. All required environmental permits shall be kept current and available on premise for review.

5. Health and Safety

Suppliers should provide a safe, clean and healthy work environment and abide by all applicable laws with respect to health, safety and the environment. This includes implementing appropriate safety procedures, training, preventative maintenance and protective equipment. Suppliers should ensure that actual and potential risks to worker health and safety are identified, assessed and eliminated or managed in order to mitigate their impacts and ensure preparedness. Suppliers should strive for continual improvement in safety performance and regularly review and update their safety programs and practices in a manner that ensures ongoing compliance with law and industry standards.

6. Business Integrity

Suppliers must demonstrate a high degree of professionalism and have a close affinity with our business ethics. Any and all forms of bribery, corruption, deception and records falsification are strictly prohibited,

whether given to obtain business or otherwise. The business relationship may be immediately impacted by any such finding. The retaliation or reprisal against any person who, in good faith, reports unlawful or inappropriate activity related to the Code and/or the audit process may also give cause to interrupt the business relationship.

7. Subcontracting

Suppliers may not subcontract any operation in the manufacturing process without prior written consent from The Earth Group, and only after the subcontractor has agreed to comply with The Earth Group’s Code. Suppliers are responsible for ensuring compliance with The Earth Group’s Code by all of their subcontractors who produce or provide materials or services which are used in the manufacturing, processing, or production of merchandise sold to The Earth Group.