NBCUniversal
Manufacturer Code of Conduct
NBCUniversal is committed to the highest standards of social and environmental responsibility and ethical conduct, and we expect the same
commitment to be shared by all manufacturers of NBCUniversal merchandise. Further, we require that all manufacturers of NBCUniversal
merchandise comply with all applicable national and local laws and regulations, including but not limited to those related to labor, immigration, health,
safety, and the environment. At a minimum, we require that all manufacturers of NBCUniversal merchandise meet the following standards:
Child Labor
NBCUniversal manufacturers will not use child labor. Production
facilities that employ individuals under 16 years of age would be
considered in violation of the Code of Conduct and subject to
immediate termination of the contract.
Student Worker Protections
The only potential exception to the Child Labor requirement is
employment pursuant to a government-approved vocational
workforce program that permits employees under 16 years to work
for educational credit on the condition that they are not exposed to
potential health or safety hazards. Manufacturers shall ensure
management of student workers through proper maintenance of
student records, rigorous due diligence of educational partners,
and protection of students’ rights in accordance with applicable
law and regulations.
Prevention of Involuntary Labor and Human Trafficking
All labor must be voluntary. Manufacturers will not use any forced,
involuntary, prison, bonded or indentured labor and shall not engage in
or support trafficking in human beings. Employees must be allowed to
maintain control over their identity documents and have the right to
leave the workplace premises after completing the standard workday.
Harassment
Each employee will be treated with respect and dignity and will not
be subject to violence, punishment, or abuse.
Nondiscrimination
Manufacturers will employ fair practices in hiring and other
employment-related practices, including but not limited to terms of
employment, salary, benefits, and advancement. Termination or other
employment actions on the basis of race, religion, age, nationality,
social or ethnic origin, gender, political opinion, or disability are
prohibited.
Freedom of Association
Employees’ rights to associate, organize, and bargain collectively
will be respected by the manufacturer without penalty to
employees.
Health & Safety
Manufacturers will provide employees with a safe and healthy
workplace in compliance with all applicable laws and regulations.
The same requirements will be met for employee housing that is
provided for by the manufacturer. Manufacturers must take
proactive measures to prevent workplace and housing hazards.
Compensation and Labor Hours
At minimum, manufacturers will comply with all applicable wage and
working hour laws and regulations, including those relating to
minimum wages, overtime, maximum hours and other elements of
compensation, and will provide legally-mandated benefits. If local law
does not require overtime pay, manufacturers will pay at least regular
wages for overtime work. Manufacturers will be entitled to at least
one day off in every seven-day period.
Protection of Environment
Manufacturers will comply with all applicable environmental laws and
regulations including local and national codes, and all laws related to
waste disposal, air emissions, discharges, toxic substances and
hazardous waste disposal.
Anti-Corruption
Manufacturers will not engage in corruption, extortion, embezzlement,
or bribery. Manufacturers and any persons acting on their behalf, will
not, directly or indirectly, give, offer, or authorize the offer of anything
of value (such as money, gifts, business entertainment, meals, travel,
discounts, jobs for relatives, charitable contributions, goods or
services), regardless of the amount of value, to a supplier, customer or
government official in order to obtain any improper advantage including
but not limited to actions taken to obtain government-issued licenses
and permits necessary for their operations. Manufacturers agree not to
offer, pay, and promise to pay, or authorize the payment of any money
or anything of value to NBCUniversal auditors. Manufacturers will
comply with all applicable anti-corruption laws and regulations of the
countries in which they operate, the U.S. Foreign Corrupt Practices Act
(FCPA), the U.K. Anti-Bribery Act, and applicable international anti-
corruption conventions.
Audits, Compliance and Corrective Actions
Manufacturers will authorize NBCUniversal and its designated partners
(including third parties) to engage in audit and monitoring activities to
review compliance with each element of this Code of Conduct,
including but not limited to, on-site inspections of manufacturing
facilities and employee housing, review of records relating to
employment, and the conduct of interviews with employees.
Manufacturers are required to maintain all documentation to
demonstrate compliance with this Code of Conduct, and to have a
process for timely correction of any deficiencies or violations identified
by an internal or external audit, assessment, inspection, investigation,
or review.
Subcontracting
Manufacturers will not use subcontractors for the manufacture of
NBCUniversal merchandise or components thereof without
NBCUniversal’s express, written, advance consent.
Revised: January 27, 2016
 NBCUniversal Audit Finding Closure Process

After the audit report is received by the factory, NBCUniversal’ s goal is that all red flag findings are
closed within 90 days, and yellow flag findings within 365 days. The factory should prepare a corrective
action plan (CAP) with specific audit finding closure actions, including projected dates of completion.

An audit closing specialist representative from our auditing company will contact the factory within the
next seven days about the follow-up process to collect electronic evidence of the corrective actions,
and to document the progress in closing findings. The audit closing specialist will also report the
progress of the factory to their NBC partners and vendor/licensee.

NBCUniversal understands that certain findings will require action by local government agencies and
therefore the timing of finding closures may be outside the control of the factory. In this event, the
factory must demonstrate its efforts to obtain permits, certifications, licenses, etc., by supplying
electronic evidence of applications, invoices, or any other certified documents as proof of their
attempt to close the finding. When official documents are issued by the local agency, copies must be
sent electronically to the audit closing specialist for review.

NBCUniversal reserves the right to conduct a follow-up audit of any manufacturing facility at any time
if needed. Annual re-audits of the factory will be conducted at the discretion of NBCUniversal.

Audit Closing Meeting Discussion Checklist:

1. Authorized factory representative is presented with preliminary findings

 Clearly specify the areas of concern/findings

 Acknowledgement of any violations of labor laws
 Advise factory of zero tolerance findings

2. Provide details on requirements to downgrade findings from Red to Yellow

3. Collect any applications that have already been submitted to government

4. Advise factory personnel of responsiveness required to close findings

5. Conference in Auditor supervisor to join the discussion

By signing this document you are confirming your acceptance of the Manufacturer Code of Conduct and the
NBCUniversal Audit Finding Closure Process in order to qualify for NBCUniversal supplier status.

Signatures Required Below:

Auditor ----------------------------------------------------------------------------------------

Authorized Factory Representative ----------------------------------------------------------------------

Date--------------------------------------------------------------------------------------------------------

Please report any violations of the Code of Conduct using the following contact information:

Integrity Concern Reporting: 1-800-622-6221

Email Address: integrity@nbcuni.com