Code of Conduct

MAKEBOX & CO CODE OF CONDUCT (Effective March 2025)

Our Commitment

At MakeBox & Co, we are committed to ethical practices throughout our supply chain. This Code of Conduct outlines our standards for labor and the environment, drawing upon the Ethical Trading Initiative's (ETI) Base Code. We aim for standards that are fair, achievable, and verifiable, fostering continuous development with our partners.

We understand our customers expect the goods and services they purchase from us to be produced by companies that:

• Operate lawfully.
• Respect and do not exploit their workforce.
• Ensure decent working conditions.
• Protect the environment.

Partnership and Improvement

Achieving these standards requires a strong partnership with our suppliers, built on trust, transparency, and cooperation. We expect open communication about labor and environmental conditions to collaboratively address any areas needing improvement.

We recognize that immediate compliance may face challenges. In these situations, suppliers must commit to a plan for continuous improvement over a reasonable timeframe, agreed upon with MakeBox & Co, to meet the Code's expectations.

Verification

MakeBox & Co representatives may conduct visits (announced or unannounced) to manufacturing sites to verify compliance. Suppliers must grant unrestricted access to facilities, including dormitories, and relevant documentation.

Responsibility and Communication

• Suppliers must designate a senior manager as the primary contact for Code-related matters.
• This Code must be communicated to all workers.
• Suppliers must ensure their own suppliers also adhere to these standards.

Legal Foundations

• Compliance: Employers must adhere to all applicable laws in their operating countries regarding employment, health and safety, and the environment.
• Immigration: Only workers legally entitled to employment under national immigration laws may be hired.
• Higher Standards: When local laws and this Code address the same issue, the provision offering greater protection shall apply.
• Scope: This Code applies to all workers, including agency, migrant, temporary, and permanent staff.
• Transparency: This Code will be publicly available on the MakeBox & Co website.

CODE OF CONDUCT STANDARDS

1. Employment is Freely Chosen 1.1. No forced, bonded, or involuntary prison labor is permitted. 1.2. Workers shall not be required to lodge deposits or identity papers and are free to leave employment after reasonable notice.

2. Freedom of Association and Collective Bargaining 2.1. Workers have the right to join or form trade unions and bargain collectively. 2.2. Employers shall adopt an open attitude towards legitimate trade union activities. 2.3. Workers' representatives shall not face discrimination and shall have access to carry out their functions. 2.4. Where these rights are restricted by law, employers shall facilitate parallel means for independent association and bargaining.

3. Working Conditions are Safe and Hygienic 3.1. A safe, hygienic working environment must be provided, considering industry knowledge and specific hazards. Measures must minimize risks of accidents and health injuries. 3.2. Regular, documented health and safety training must be provided, repeated for new or reassigned workers. 3.3. Access to clean toilets, potable water, and, where applicable, sanitary food storage facilities must be provided. 3.4. Employer-provided accommodation must be clean, safe, and meet workers' basic needs. 3.5. A senior manager must be assigned responsibility for health and safety.

4. Child Labour Shall Not Be Used 4.1. There shall be no recruitment of child labor. 4.2. Policies must support transitioning any child found working into quality education until they are no longer considered a child (as defined by ILO conventions). 4.3. Children and young persons under 18 shall not work at night or in hazardous conditions. 4.4. Policies must align with relevant ILO standards.

5. Living Wages are Paid 5.1. Wages and benefits for a standard work week must meet, at minimum, national legal or industry benchmark standards (whichever is higher), sufficient for basic needs and some discretionary income. 5.2. Workers must receive clear, written information about wage conditions before starting employment and details with each pay period. 5.3. Wage deductions as disciplinary measures are forbidden. Deductions not mandated by law require explicit worker permission. Disciplinary actions must be recorded.

6. Working Hours are Not Excessive 6.1. Hours must comply with national laws, collective agreements, or points 6.2-6.6 (whichever offers greater worker protection). 6.2. Standard weekly hours (excluding overtime), defined by contract, shall not exceed 48 hours*. 6.3. All overtime must be voluntary, used responsibly (considering frequency, duration, and individual impact), and not replace regular employment. Overtime must be paid at a premium rate (recommended minimum 125% of regular pay). 6.4. Total hours in a 7-day period shall not exceed 60, except as per clause 6.5. 6.5. Exceeding 60 hours/week is permissible only in exceptional circumstances if allowed by national law and a collective agreement, with worker safeguards, and demonstrable justification (e.g., unexpected peaks, emergencies). 6.6. Workers must receive at least one day off per 7 days (or 2 days off per 14 days if allowed by law). *International standards recommend progressively reducing normal hours to 40/week where possible, without reducing wages.

7. No Discrimination is Practised 7.1. No discrimination in hiring, pay, training, promotion, termination, or retirement based on race, caste, origin, religion, age, disability, gender, marital status, sexual orientation, union membership, or political affiliation.

8. Regular Employment is Provided 8.1. Work performed must, as far as possible, be based on a recognized employment relationship established through national law and practice. 8.2. Obligations to employees under labor/social security laws shall not be avoided through labor-only contracting, subcontracting, home-working, or non-genuine apprenticeship schemes, nor via excessive use of fixed-term contracts.

9. No Harsh or Inhumane Treatment is Allowed 9.1. Physical abuse or discipline, threats, sexual or other harassment, verbal abuse, and other forms of intimidation are strictly prohibited.

10. Modern Slavery and Forced Labour are Prohibited 10.1. All forms of modern slavery and forced labor are prohibited. 10.2. Workers must not be threatened with financial penalties. 10.3. Overtime must be voluntary; consent must be regularly re-established and documented. 10.4. Workers must be free to leave the worksite/accommodation and choose their own housing. Permission is not required to leave the country or place of work. 10.5. Wages must not be deliberately withheld. Workers cannot be forced into debt bondage. 10.6. Direct recruitment is preferred. If agencies are used, workers must have clear contracts, and agreements between parties must be available for review. 10.7. Workers must not pay recruitment fees. The employer bears the full cost of recruitment and placement (including fees, transport, visas, health checks, permits) in both origin and work countries. Records must be kept.

11. The Environment is Protected 11.1. Employers must comply with all national environmental laws and regulations and operate according to relevant international environmental standards and agreements.