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Appendix 2

CODE OF CONDUCT
GENERAL PRINCIPLES
AND
STANDARDS
~
DETAIL GUIDELINES

04/2008
Appendix 2

TABLE OF CONTENTS PAGE


1. FORCED LABOR .............................................................................................................. 1
Contract Labor...................................................................................................................... 1

2. CHILD LABOR ................................................................................................................. 3

3. HARASSMENT OR ABUSE ................................................................................................ 4

4. HEALTH AND SAFETY ..................................................................................................... 5


a) Ventilation....................................................................................................................... 5
b) Drinking Water ............................................................................................................. 6
c) Toilet Facilities ............................................................................................................... 7
d) Lighting ........................................................................................................................... 8
e) Equipment Safety .......................................................................................................... 10
f) Protective Equipment ................................................................................................... 12
g) Hazardous Material ...................................................................................................... 17
h) First Aid Equipment .................................................................................................... 21
i) Aisles, Exits and Stairwells .......................................................................................... 24
j) Fire Safety Equipment ................................................................................................. 27
Electrical Safety ............................................................................................................. 34
k) Emergency Evacuation ................................................................................................. 36
l) Dormitory / Living Facilities ..................................................................................... 37

5. NONDISCRIMINATION ................................................................................................... 43

6. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING ...................................... 44

7. WAGES AND BENEFITS ................................................................................................... 45

8. WORK HOURS AND OVERTIME ..................................................................................... 48

9. COMPLIANCE WITH LAWS .............................................................................................. 50

10. ENVIRONMENT ............................................................................................................... 51

11. SUBCONTRACTORS ......................................................................................................... 52

12. CODE OF CONDUCT POSTER......................................................................................... 53

04/2008
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1. FORCED LABOR

There shall not be any use of forced labor, whether in the form of prison
labor, indentured labor, bonded labor or otherwise.

Common types of Forced Labor :

Prison Labor
Incarcerated person forced to work as a condition of his / her sentence.
Indentured Labor
Person forced to work by an employer who forbids the worker from leaving employment
at his / her discretion.
Bonded Labor
Person working not for compensation but to pay off a debt incurred by another in
exchange for the worker’s labor.
Forced Overtime
This may occur when a person is required to work beyond the normal working hours /
days on an ongoing basis as a mandatory condition of employment. In such a case, the
violation results from the fact that the worker does not have the freedom to refuse
working overtime without risking reprisals.
Freedom of Movement
Unreasonable restrictions on workers’ freedom of movement can be an indicator of
forced labor. Workers should be allowed to leave the factory under reasonable conditions
and any cases where they are physically barred from leaving the factory at will should be
cause for concern.

Contract Labor

Although contract labor is not considered to be forced labor, there are many instances where
contract labor conditions cause it to fall under forced labor.

In countries where the local workforce is in short supply, the local government may have a
scheme to allow the importation of workers from other countries. In such cases, the
imported worker is employed on a fixed term contract which is generally a 2-3 year time
period. Ideally the contract labor system should benefit both the worker and the factory,
with the factory getting a stable supply of labor that allows it to continue operations and the
worker earning a wage that is significantly higher than in his / her home country while
learning skills that enhance his / her future employment prospects.

In part as a solution to the problems and complexities of finding workers abroad, a system
has developed whereby the services of labor brokers in both the workers’ home countries and
the labor-receiving countries are engaged to recruit workers and handle all paperwork
processing. These brokers are generally licensed by the government of both countries. While

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the factories’ use of labor brokers is strictly a business decision, the recruitment practices of
many of these brokers present significant risks in the area of work exploitation and
compliance with labor standards.

The key problem in the contract labor system lies in the level of fees that potential workers
must pay at various stages of their hiring process. The factory generally pays no recruitment
fee but rather all costs are borne by the individual worker. In some cases, workers have to
borrow locally the entire sum needed to pay the labor broker in order to secure the job.
These loans are taken at exorbitant interest rates, with homes and farms being used as
collateral. Workers who are subsequently sent home for any reason, risk losing their families’
property. In other cases, the labor broker’s fee is settled by salary deductions from each
worker which in many instances means that the workers have negative salaries for significant
periods of their contract.

In either case, the worker finds themselves having to incur excessive debt as a condition of
securing employment. This situation leads itself to worker exploitation and abuses arising
out of the fact that the workers are so heavily in debt that they live in fear of being sent
home before they have completed their contract. In order to identify and uncover any such
cases, we require our factories to provide an explanation if any of the following practices are
found :

Contract workers are paid less than the legally mandated minimum wage applicable to
their status.
Contract workers are paid less than the terms specified in their contract.
Contract workers’ passport or other personal identification documents are retained by
another party.
Substantial amounts are being regularly deducted from the contract worker’s salary.
The contract worker was required to leave a deposit with either the factory or the labor
broker that consists of a substantial sum of money.

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2. CHILD LABOR

No person shall be employed at an age younger than 15 (or 14 where the


governing law allows such employment), or younger than the age for
completing compulsory education if the age in the country of
manufacture is greater than 15.
All facilities are required to maintain official documentation in order to
verify each worker’s date of birth, as well as appropriate records
documenting that the employer adheres to all restrictions under local
labor laws that apply to juvenile workers.

Under our Code of Conduct we have established 15 years of age as being the minimum
working age for workers employed by our suppliers, with the following provisions :
1. If local governing law mandates a higher minimum working age then, our suppliers
are required to comply with the local law.
2. If local governing law allows employment at 14 years then, this is allowable.
It is important to note that while most countries permit employment of persons between
ages 14-18, they generally impose legal restrictions on the number of work hours, work
time and nature of work that these persons can take up.
To ensure that no child labor is employed in facilities producing private label
merchandise for Macy’s, we require that suppliers physically maintain on-site
documentation that verifies each worker’s date of birth. The type of documentation may
vary from country to country but it is the supplier’s responsibility to provide
documentation that is genuine and irrefutable. Common documentation would include:
1. Birth Certificate
2. Education Certificate
3. Passport
4. Government Identification Card
All suppliers are also required to maintain documents verifying their compliance with
any / all legal restrictions as relates to juvenile workers.
For ease of monitoring and to ensure that the factory is fully aware of the legal
restrictions on juvenile workers, the factory should maintain separate records for workers
whose age falls within the category of “with legal restrictions”.

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3. HARASSMENT OR ABUSE

Workers shall be treated with respect and dignity. Workers shall not be
subject to any physical, verbal, sexual or psychological harassment or
abuse in connection with their employment.
There is to be no use of corporal punishment.

We require that our suppliers treat all workers with respect and dignity. Factories are
strictly forbidden from using corporal punishment as well as engaging in or permitting
any form of physical and mental coercion which includes the following :
1. Sexual Harassment
2. Threats of Violence
3. Verbal Abuse

Best Practices :

To ensure both workers and suppliers are fully aware of the importance of maintaining a
harassment-free working environment, suppliers are recommended to :

Maintain a formal written anti-harassment and abuse policy, communicating the content
of the policy to all workers.
Maintain a complaint / incident report record for every alleged harassment incident.

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4. HEALTH AND SAFETY

Employers shall provide a safe and sanitary working environment in


order to avoid preventable work related accidents and injuries.

a) Ventilation

Factories should have adequate circulation and ventilation.

Poor ventilation can damage worker’s health and their productivity. While it is
recognized that the outside air temperature has the most significant impact on the air
temperature of a facility, suppliers should make all efforts to :
Maintain reasonable air circulation
Reduce temperature extremes
Remove toxic and particulate matter from the air
Install mechanical ventilation devices in areas where welding, spraying and polishing
take place to remove toxic fumes
Keep factory floor swept or vacuumed

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b) Drinking Water

Free potable water should be reasonably accessible to all workers throughout the
working day.

Workers should be provided with drinking water that is :


Clean and hygienic
Stored in a sanitary manner
Accessible without unnecessary restriction

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c) Toilet Facilities

Workers should have access to reasonably clean and private toilet facilities in
adequate numbers for each sex. We recommend that facilities maintain a toilet to
worker ratio of 1 to 30.

Toilet facilities must :


Be clean, sanitary and odorless
Be well-ventilated
Have running water
Have appropriate privacy
Be segregated by gender
Be accessible without unnecessary restriction
Be adequate in number

Best Practices :

To promote clean and healthy toilet facilities for workers, suppliers are recommended to:
Maintain a toilet to worker ratio of 1 to 30
Maintain a cleaning schedule / log book
Provide soap, toilet paper and hand drying capabilities
Mount signage in the facilities to remind workers of the importance of cleanliness.

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d) Lighting

Work areas should be sufficiently lit so that manufacturing tasks may be safely
performed. We recommend the following standards :
Cutting, Assembly and Finishing Operations ………………………… 50-80 ft. candles
Inspection ………………………………………………………………………………… 80-100 ft. candles
Storage ……………………………………………………………………………………… 30-50 ft. candles

Lighting is an important factor in minimizing accidents and as such, factories need to


control all illumination aspects which include :
Type
Intensity
Diffusion
Location
Glare
Shadow Control

To ensure all work surface lighting is adequate for the safe performance of relevant
production activities, a light meter should be used to measure the illumination level of
each production area.

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Best Practices :

Some lighting level recommendations :

Storage Area ……………………………………………………………………………………… 30-50 ft. candles


Cutting, Assembly and Finishing Operations Area ………………………… 50-80 ft. candles
Inspection Area ………………………………………………………………………………… 80-100 ft. candles

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e) Equipment Safety

All equipment should be tested regularly and properly maintained. Operational


safety devices should be installed on equipment where appropriate.

Operation of machinery presents a safety hazard, which in many instances, could be life
threatening. The factory must ensure that any machine part, function or process which
may cause injury is safeguarded.

To minimize any potential hazards caused by the use of equipment and machinery, the
following measures should be adopted :
Workers should be trained in the safe operation of all equipment and machinery that
they use.
All equipment should be regularly tested and maintained by trained personnel.
Loose-fitting clothing & accessory articles that could get caught in machinery should
not be worn.
Water, grease or materials on the floor should be cleaned up promptly to prevent
slips and falls onto equipment.
All machinery should be equipped with lock out capability. In addition, machines
should be locked in the OFF position before any cleaning.
All equipment and machinery should be securely placed and anchored where
necessary to prevent tipping or other movement that could result in personal injury.
Dangerous machinery should be operated only with two-hand equipment. Safety
guards should be fitted on all machinery with such requirements.
Machinery should not be left running while unattended.
There should be sufficient clearance between machines to allow for safe operation, set
up and servicing, material handling and waste removal.

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Best Practices :

Potential hazard warning signs are recommended to be mounted on, around or near to
dangerous machinery in order to help reduce injuries.

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f) Protective Equipment

Where appropriate, factories should make available personal protective equipment to


workers performing hazardous tasks.
Workers should not be exposed for extended periods to noise levels above 80
decibels without being required to use factory provided safety equipment.

Personal protective equipment can provide a last defense against injury when other
hazard control measures have failed. We require our suppliers to :
Furnish their workers with personal protective equipment that is appropriate based
on the nature of their job.
Educate their workers on the importance of wearing the personal protective
equipment.

Once specific hazards are identified, appropriate equipment must be supplied to protect
workers from physical injury. This protection may include :
Foot Protection
Foot protection is important to prevent injuries in case a heavy or sharp object falls
on a worker’s foot or a worker steps on an object that could pierce his / her shoe.

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Head Protection
Hard hats are intended to protect workers from impact and penetration caused by
objects that could fall on their head. In addition, they also provide limited
protection from electrical shocks or burns. All workers should wear hard hats when
performing work under scaffolds or overhead cranes, forklifts, loaders boom trucks or
any other equipment that is handling materials.

Eye and Face Protection


Appropriate eye and face protection should be worn by all workers exposed to any of
the following hazards :
- Toxic / Hazardous Liquids and Gases
- Flying Particles and Dust
- Molten Metals
- Persistent Glare
It is important that eye and face protective equipment be comfortable to wear yet fit
securely without interfering with vision or movement. The type of eye and face
devices selected should provide adequate protection against the specific hazard that
has been identified.
- Safety Glasses
Must have impact-resistant lens and a strong frame to protect the wearer from
flying particles.
- Safety Goggles
Should be designed to provide a shield around the entire eye area to protect against
hazards from many different directions.
- Face Shields
Must provide full face protection against sparks, splashes and splatter. They
provide secondary eye protection and must be worn with protective glasses or
goggles.

Safety Glasses Safety Goggles Face Shields

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Ear Protection
Extended exposure to excessive noise can cause permanent hearing loss. Hearing loss
is progressive and as such, we require that our suppliers provide hearing protectors to
all workers who are exposed to noise levels above 80 decibels for extended periods of
time.
- Ear Plugs
These should be made of soft, expandable foam for comfortable fitting and
enhanced noise reduction.
- Ear Muffs
These should have soft, foam-filled ear cushions that provide excellent sealing,
comfort and low surface pressure. The ear muff should be adjustable to fit different
head sizes.

Ear Plugs Ear Muffs

Hand Protection
Hands must be protected to prevent possible hazards such as severe lacerations,
abrasions, punctures, chemical and thermal burns, temperature extremes, electric
shock and etc. Suppliers must provide workers with appropriate type of gloves to
protect them against identified potential safety hazards.

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The length and type of cuff on a glove should be appropriate to its functionality.
- Pinked Cuff
Has a zigzag appearance and is designed to catch drips in the cuff.
- Rolled Cuff
Acts as a barrier to keep chemicals from running off glove onto skin.
- Straight Cuff
Protects skin from chemical run-off.
- Knitwrist Cuff
Absorbs perspiration and adds temperature protection.
- Gauntlet Cuff
Has flared design and extended length to protect wrist and forearm.

Body Protection
Lightweight aprons and overalls should be provided to workers whose torso may be
exposed to spilled fluids and contact with particulates of extreme temperature. The
dimensions, material composition, finish and etc. should be appropriate to provide
protection from the identified potential hazard.

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Respiratory Protection
In workplaces that pose a potential health hazard due to inhalation of airborne
contaminants such as dust, mist, fumes, gas and vapor, suppliers are required to
provide their workers with respiratory protective equipment. It should be
permanently assigned to individual workers for their exclusive use.

Best Practices :

Warning signs are recommended to be posted at the entrances to or on the periphery of


all work areas/operations in which workers require the usage of personal protective
equipment.

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g) Hazardous Material

Hazardous and combustible materials should be stored in secure, well-ventilated


areas and should be properly labeled and posted with safety and warning signage.

To safeguard the safety and health of all workers and the public, suppliers are required to
ensure that the handling, storage and labeling of hazardous and combustible material is
carried out in a safe and secure manner. Moreover, all suppliers must adhere to
applicable local environmental, safety and health regulations.

The ability of a material to act as a fuel is defined as combustibility. Combustible


materials are those materials that can ignite and sustain a fire. The most dangerous
substances are those with low ignition temperature, law explosion limit and wide
flammability range.

Handling
- All employees that work or come into contact with hazardous materials should be
required to wear the appropriate personal protective equipment.
- Employees should be trained and must follow proper clean-up procedures in
handling minor spills. Any spills of a toxic substance that are consisted major
should be handled by a person who is specially trained to evaluate the toxicity and
flammability.
- For every chemical that the factory uses that may pose a health hazard, written
emergency measures should be formulated to deal with any cases of employee
exposure. Personnel should be trained in summoning proper assistance, whether by
notifying a supervisor or obtaining first aid medical assistance. Chemicals on the
body or in the eye should be washed with large quantities of water and factories
should maintain on-site flushing facilities/stations for face, eyes and body as
required.

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Storage
- The amount of chemicals and flammable materials stored on-site should be kept as
small as is feasible. This reduces the possibility of large amounts of hazardous
chemicals becoming involved in a fire.
- Dependable containers made of cold rolled steel or high density seamless
construction polyethylene (HDPE) should be used.
- Proper segregation of stored chemicals is necessary to prevent incompatible
materials from inadvertently coming into contact, which fire, explosion, violent
reactions or toxic gases could result.
- Safety cabinets are a convenient and secure means of storage for flammables,
corrosives, acids, paints and ink.
- No eating, drinking or smoking should be allowed in the vicinity of materials.
- The storage area must be provided with secondary containment and have an
impenetrable base underlying the containers that is free of cracks or gaps which
could contain spills and leaks from tipped, overfilled or ruptured containers.

Labeling
All containers should have labels that provide essential information in a language that
is understandable to all workers. A worker should be able to tell at a glance the
dangers associated with the chemical. A well-written label can tell the workers exactly
what to do to protect themselves and what can happen it they handle the chemical
improperly. Labels should have the following key information :
- Chemical Name
This should list the common or chemical name, or both, of the substance.
- Company Name
Name, address and emergency telephone number of the manufacturer or importer
of the chemical.

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- Health Hazard
This should provide information on possible health problems that could result
from over exposure.
- Physical Hazard
This should provide information on what could happen if the chemical is not
handled properly. It should give information on flammability or combustibility,
explosivity, reactivity or radioactivity.
- Storage and Handling
Details on the recommended and required handling should be included, i.e. - “use
in well-ventilated areas”, “keep away from sparks, heat and flame”, “do not store
near combustible materials”., etc.

Areas where toxic chemicals/hazardous and combustible materials are stored or used
should be prominently posted with safety and warning signage.

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Best Practices :

A color and number-coded label system has been developed to quickly assist users in
recognizing the danger levels of chemicals. We recommend that suppliers choose to
follow either the National Fire Protection Association (NFPA) or the Hazard Material
Information System (HMIS) classifications for hazardous materials.

HAZARD COLOR KEY NUMBER CODE


Red Fire Hazard 0 Minimal
Blue Health Hazard 1 Slight
Yellow Reactivity Hazard 2 Moderate
Specific Hazards or 3 Serious
White
Protective Equipment 4 Extreme

NFPA
This system uses a four color, diamond panel with color
and number codes to indicate the type of hazard and
level of danger associated with that hazard.

HMIS
The HMIS uses a vertically stacked color bar to
provide the pertinent information.

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h) First Aid Equipment

Each factory should maintain an adequate number of well-stocked, visible and easily
accessible first aid kits.

We expect our suppliers to make every attempt to prevent accidents in their factories. In
the absence of an on-site infirmary or clinic, all factories are required to maintain an
adequate number of first aid kits that are :

Well-stocked.
Visible and easily accessible.
Inspected periodically and re-stocked when necessary.
Packaged in sanitary and sturdy boxes / containers.
Mounted on walls with proper signage.
Located in areas that facilitate emergency treatment within 3-4 minutes of an injury
taking place.
Appropriate to treat all types of medical emergencies.
Available at every production site.
Sufficient to support the size of the workforce.

Moreover, a sufficient number of employees should be trained in the administration of


first aid.

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Signage should be mounted on, around or near to first aid equipment for ease of
identification.

Best Practices :

The National Safety Council recommends the following supplies be maintained in a first
aid kit.

Bandages /
Medicine / Ointments Equipment
Dressing Materials

Eye Wash Triangular Bandage Regular Scissors


Eye Lotion Gauze Pads 2”, 3” & 4” Blunt-Tip Scissors
Antiseptic Wipes Non-Adherent Pads 2”, 3” & 4” EMT Shears
Alcohol Prep Pads Adhesive Strip bandages Tweezers
Antibiotic Ointment Trauma Dressing 5”x9” / 8”x10” Disposable Latex Gloves
Hydrocortisone Cream 1% Gauze Roller Bandages 1” & 2” Mouth-To-Barrier Face
Antifungal Cream Adhesive Tap ½” or 1” Mask
Calamine Lotion Eye Pads Thermometer
Aspirin Duct Tape Penlight
Ammonia Inhalants Cotton Tips 3” Light Stick
Elastic Roller Bandages 2”, 3”, 4” & 6” Cold Pack

In facilities which employ a large workforce, the factory should consider setting up an in-
house clinic to treat minor injuries.

Where the eyes or body of a worker may be exposed to injurious corrosive materials, an
eyewash station capable of flushing the eyes for 15 continuous minutes at a rate of 0.4
gallons per minute is an integral part of first aid. Workers must be trained to use the
equipment.

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Emergency telephone numbers should be posted in conspicuous places near or on


telephones.

For record and control purpose, the factory should maintain an injury log.

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i) Aisles, Exits and Stairwells

We require that each enclosed manufacturing facility have an adequate number of


clearly marked, unlocked exits in order to facilitate an effective evacuation in case of
emergency. By adequate, it is means that each workstation should be within 200 feet
of an exit. All exits should have battery operated emergency lights placed above
them.
Aisles, exits and stairwells should be kept clear of any obstructions that could
prevent the orderly evacuation of workers. Exit stairwells and corridors and aisles
leading to them are required to be at least 22 inches wide. It is recommended that
they be at least 44 inches wide. Exits should be at least 33 inches wide.

Obstructed aisles and locked or insufficient number of exits are the most frequently cited
safety hazard. Most importantly though, they are recognized as making the most
difference between life and death in emergency evacuation situations. As such, the
following provides details of our minimum requirements.

Aisles and Stairwells

All aisles, corridors and stairwells leading to exits must be clear of any obstructions.
Exit stairwells and aisles must be a minimum of 22 inches wide.
Secure handrails must be fitted on all stairways with 4 or more steps.

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Exits

Must be adequate in number, with no worker having to travel more than 200 feet
from their workstation to the nearest exit.
Must be clearly marked by a readily visible sign and be free of any obstructions.
Must be unlocked from the inside of the workplace premise at all times during
working hours.
All exits must be a minimum of 33 inches wide.
All exits should have battery operated emergency lights placed above them.
All exit doors must swing out.
If an exit is not easy to find, the path to that exit must be pointed out by placing a
sign reading “Exit” which contains an arrow in every location where the direction of
travel leads to the exit.
Every exit sign must have the word “Exit” 6 inches high using plain, legible letters no
less than ¾ inches wide and be visible from 100 feet away.
Any door, passage, or stairway that is neither an exit nor a way of exit access and is
likely to be mistaken for an exit, must be identified by a sign, reading “Not An Exit”
or similar wording. It may also be identified by a sign indicating its actual character
or use, such as “Storage Room”, “To Basement”, etc.

“Exits” Signage

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“Not An Exit” Signage

Best Practices :

To enhance safe and expedient evacuation, we recommend the following :

Aisles and Stairwells

Exit stairwells and aisles should be at least 44 inches wide.


Stairway surfaces should be provided with a finish that renders them slip resistant.
Steps on stairways should be fairly uniform from top to bottom and should rise no
more than 4 inches and have a depth of at least 10 inches.
Steps should be constructed to accommodate a load of 1,000 pounds.

Exits

All exits and evacuation routes should be well-illuminated.


Evacuation paths should be marked on the floor.
All exits should be at least 44 inches wide.
Glow-in-the dark signage and marking be used to provide maximum visibility during
day and night.

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j) Fire Safety Equipment

Each facility should have appropriate fire prevention capability based upon the size
of the facility and number of workers normally occupying the premises. While we
recommend that facilities install fire hoses, extinguishers, overhead sprinklers,
alarms, photoluminescent exit routes marked on the floor and other warning and
control devices, our minimum standard, where fire hoses or overhead sprinklers are
not present, is one fully charged fire extinguisher within 75 feet of each work
station.
Fire extinguishers should be properly maintained and inspected annually, tagged
with the most recent inspection date, and properly deployed throughout the
premises to be visible and accessible to workers in case of fire.

Fires are a major cause of injury, death and property damage and they represent one of
the most frequent safety hazards in all manufacturing facilities. There are many causes of
industrial fire including :

Electrical due to wiring and poor maintenance of equipment


Cigarette smoking
Frictions from hot bearings, jammed or broken machine parts
Overheated materials
Burner flames from improper use of torches, ovens, etc.
Molten substances
Spontaneous ignition from oily waste and rubbish
Cutting and welding
Lighting
Chemical action

All manufacturing facilities must strive to protect all workers who may be exposed to fire
hazards as a result of the factory’s activities. Location of equipment and machinery,
material selection, building specifications and other decisions influencing fire safety
should be carefully made to minimize exposure. In addition, all factories must
implement internal procedures to comply with the following :
Only nonflammable solvents are used for cleaning and degreasing, with the use of
gasoline and similar flammable products for this purpose prohibited.
All work areas must be keep free of combustible materials.
Flammable and combustible liquids are only stored in approved, properly labeled
safety cans with self-closing lids.
Oily rags are only placed in approved, covered metal containers.

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No open fires are used in facilities, with “no smoking” signage being prominently
mounted.
Smoking restrictions are obeyed, with all cigarette butts being discarded in approved
containers - never in waste baskets or trash cans.

Smoking Restriction Signage

Fire can spread at terrifying speeds and as such, all factories must prioritize means in
which fires can be extinguished before they spread. The installation of fire extinguishers
is the easiest and lowest cost fire prevention measure.

There are many different types of fire extinguishers that are suitable for fire fighting
depending on the material and operation in a specific area :

Class A Ordinary combustible material fire


of an organic nature
Class B Flammable liquid, gas or grease fire
Class C Energized-electrical equipment fire

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All fire extinguishers should be :

Maintained and annually inspected.


Tagged with the most recent date of inspection.
Visible to all workers.
Located in accessible areas that are clear of any blockages or obstructions.
Readily accessible by each worker within 75 feet of their workstation, where fire hoses
or overhead sprinklers are not present.

Signage should be mounted on, around or near to fire extinguishers for ease of
identification.

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Best Practices :

To optimize visibility, we recommend signage to be mounted as follows :

2-Way Signs
For use in corridors and large rooms so that they can be seen from 2 directions.

3-Way Signs
Can be seen from any angle or distance.

Wrap-around decal signs


For fire extinguishers mounted on columns.

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In areas that may not be illuminated under emergency conditions, signs should
automatically light up in the dark by means of either battery-operated illumination or
using a photoluminous compound (“glow-in-the-dark”) in the sign manufacturing
process.

All workers should periodically be advised of the location and type of fire extinguishers
in their area as well as being instructed in the proper use and operation of fire
extinguishers. If flames are less than two feet by two feet, workers should be encouraged
to use fire extinguishers to put out a fire. If however the flames are larger than two feet,
workers should be instructed to evacuate the area immediately.

Operating instructions on the use of a fire extinguisher should be placed in the local
language(s) on or near each fire extinguisher.

04/2008 31 General Principle & Standards - Health and Safety


Appendix 2

Best Practices :

In addition to fire extinguishers, we also recommend that all facilities install additional
fire prevention capabilities as per the following :

A fire alarm system that is audible throughout the facility.


Overhead sprinklers.
Functioning fire hoses of at least 30 meters in length with a range of 6 meters.
Photoluminescent exit routes marked on the floor.

Factory equipped with water pool supply for use in fire emergency.

Signage should be mounted on, around or near to supplementary fire safety equipment.

04/2008 32 General Principle & Standards - Health and Safety


Appendix 2

In an emergency, immediate response helps save lives and property. To eliminate panic
and confusion when a crisis occurs, it is recommended that a self-adhesive label with
details of all emergency contact numbers be placed on every telephone.

04/2008 33 General Principle & Standards - Health and Safety


Appendix 2

Electrical Safety

Electricity is one of the best power sources ever discovered. However, when improperly
handled, it can be deadly. Electricity is the leading cause of industrial fires and as such,
electrical safety is directly linked to fire safety since overloaded or improperly maintained
electrical wiring can lead to fire. There are a number of control measures that can be taken
to eliminate or minimize electrical hazards :

Electrical cords on all machines should be in good condition and continuous in length
without any cuts, splices or taped repairs.
Electrical equipment should be grounded, i.e. - containing a third prong.
Electrical wiring should be encased with no bare or frayed wires or loose connections.
Control / electrical panels are covered and labeled.
Permanent equipment should have permanent wiring.
Ensure that circuits, motors or other electrical equipment is not overloaded, being
routinely checked for excessive warming.
Locate electrical equipment such as transformers, control boards and fuse boxes in special
rooms where access is limited to qualified workers.
Erect fences, frames or other barriers around electrical equipment and machinery.
Tight-fitting covers or plates should be provided for all electrical enclosures such as
switches, receptacles, junction boxes and etc.
Keep all work areas dry so water cannot become an electrical conductor.

04/2008 34 General Principle & Standards - Health and Safety


Appendix 2

Warning signs should be placed around electrical equipment and machinery.

Boiler and electrical junction boxes enclosed in mesh for worker safety.

04/2008 35 General Principle & Standards - Health and Safety


Appendix 2

k) Emergency Evacuation

Factories should conduct a minimum of one emergency evacuation drill per year.
Emergency evacuation diagrams should be posted and clearly visible to employees.

Situations may arise in a facility which necessitate the speedy evacuation of all workers in
order to safeguard their health and safety. To be properly prepared for such instances, we
require all facilities to implement the following measures:

Carry out a minimum of one emergency evacuation drill per year.


Ensure that emergency evacuation diagrams, showing the nearest evacuation route at
each workstation, are posted and clearly visible to all workers.

Emergency Evacuation Diagrams

Fire Drill

04/2008 36 General Principle & Standards - Health and Safety


Appendix 2

l) Dormitories / Living Facilities

The following standards shall apply where workers are housed in facilities provided by
the manufacturer :
Facilities should have adequate ventilation and circulation.
Free potable water should be readily accessible.
Clean and private toilet and bathing facilities should be reasonably accessible.
Living spaces should be segregated by gender.
Each housing facility should maintain an adequate number of well-stocked, visible
and easily accessible first aid kits.
Each housing facility should have an adequate number of unlocked and clearly
marked exits for evacuation in case of emergency.
Aisles, exits and stairwells should be kept clear from any obstructions that could
prevent orderly evacuation. Exits should be at least 33 inches wide. All exits should
have battery operated emergency lights placed above them.
Each living facility should have appropriate fire prevention capability based upon
the size of the facility and number of workers normally occupying the premises.
The minimum standard, where fire hoses or overhead sprinklers are not present, is
one fully charged fire extinguisher per 1,000 square feet of living space.
Fire extinguishers should be properly maintained and inspected annually, tagged
with the most recent inspection date, and properly deployed throughout the
premises to be visible and accessible to employees in case of fire.
A minimum of one emergency evacuation drill per year should be conducted.
Emergency evacuation diagrams should be posted and clearly visible to employees.
The living space per worker in their sleeping quarters must meet all minimum legal
requirements. We recommend that each worker be provided with a minimum of 50
square feet of space exclusive of common areas and that individual mats or beds be
provided to each worker.

In many facilities where our merchandise is manufactured, the workforce is comprised of


migrant workers from other regions and/or countries. In such cases, it is a general
practice for the factory to provide accommodation for these workers. In order to ensure
that a safe and healthy environment exists in these dormitories and living quarters, we
have adopted the following minimum requirements :

04/2008 37 General Principle & Standards - Health and Safety


Appendix 2

Poor ventilation can damage a worker’s health. Suppliers should ensure that sleeping
quarters have windows to the outside, with fans and/or heaters provided for better
temperature control.

Workers must have unrestricted access to drinking water that is clean, hygienic and
stored in a sanitary manner.

Toilet and bathing facilities which are clean, sanitary and private must be accessible to
all workers without unnecessary restrictions.

Toilet Facilities

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Appendix 2

Bathing Facilities

All living areas must be segregated by gender.

Each housing unit must have an adequate number of well-stocked, visible and easily
accessible first aid kits. A sufficient number of dormitory residents should be trained
in the administration of first aid.

04/2008 39 General Principle & Standards - Health and Safety


Appendix 2

All aisles and stairwells leading to exits must be clear of any obstruction. Each
housing unit must have an adequate number of clearly marked and unlocked exits for
use in emergency evacuation. All exits should have battery operated emergency lights
placed above then.

Aisles Exits

All housing facilities must have appropriate fire prevention capability based upon the
physical size of the facility and the occupancy level. Where fire hoses and sprinklers
are not present, we require a minimum of one fully charged fire extinguisher for every
1,000 square feet of living space.
Fire extinguishers should be :
- Maintained and annually inspected.
- Tagged with the most recent date of inspection.
- Visible to all workers.
- Located in accessible areas that are clear of any blockages or obstructions.

Fire Safety Equipment

04/2008 40 General Principle & Standards - Health and Safety


Appendix 2

Emergency evacuation diagrams, showing the nearest evacuation route at each


location in the housing facility, must be posted and clearly visible to all workers.
Moreover, a minimum of one emergency evacuation drill must be carried out per
year.

The living space allotted to each individual worker in their sleeping quarters must
meet any/all local law requirements.

04/2008 41 General Principle & Standards - Health and Safety


Appendix 2

Best Practices :

We also recommend that all facilities adopt the following standards:

Each worker should be provided with a minimum of 50 square feet of living space in
their sleeping quarters, exclusive of common areas.
Each worker should be provided with individual mats or beds.
Hot water should be provided in all bathing facilities.
All toilets should have soap, toilet paper and hand drying capabilities.
All emergency exits should be at least 44 inches wide.
Secure handrails should be fitted on all stairways and stairway surfaces should be
provided with a finish that renders them slip resistant.
All workers are provided their own storage space for their clothes and personal
possession.
All sleeping quarters to have adequate lighting.
Dormitory residents are free to come and go during their off-hours under reasonable
limitations imposed for their safety and comfort.

04/2008 42 General Principle & Standards - Health and Safety


Appendix 2

5. NONDISCRIMINATION

Workers should be employed and compensated based upon their ability


to perform their job, rather than on the basis of gender, race, religious or
cultural beliefs.

While we recognize and respect that there are cultural and legal differences between the U.S.
and many of the countries in which our products are manufactured, we nevertheless require
that all our suppliers employ and compensate workers based upon their ability to perform,
without regard to gender, age, religion or cultural beliefs.
It is an unacceptable practice to ask female workers about their pregnancy status or to require
a pregnancy test when applying for a position at the factory or at any time during their
employment. This is considered as a serious form of discrimination.

Best Practices :

To ensure both workers and suppliers are fully aware of the importance of maintaining an
equal opportunity workplace, suppliers are recommended to :

Maintain a formal written anti-discrimination policy and communicate the contents of


the policy to all workers.
Maintain a complaint / incident report record for every discrimination allegation made
by a worker.

04/2008 43 General Principle & Standards – Nondiscrimination


Appendix 2

6. FREEDOM OF ASSOCIATION AND


COLLECTIVE BARGAINING

Suppliers should respect the rights of employees to lawfully associate or


not to associate with groups of their choosing, as long as such groups are
legal in the country where the merchandise is manufactured. Supplier
should not interfere with, obstruct or prevent legitimate related
activities.

All workers should have the legal right to free association and they should be made aware of
this right. Also, all workers should have the legal right to form and join unions without any
penalties or reprisals. Factory management should not interfere should workers join unions
or engage in other worker organizations.

Best Practices :

There are one or more workers’ representative at the factory.


Factory management consults with employee representatives in establishing working
conditions for the well being of workers.
Factory management has regular meetings with worker representative.

04/2008 44 General Principle & Standards – Freedom of Association and


Collective Bargaining
Appendix 2

7. WAGES AND BENEFITS

Wages and Benefits


Employers should recognize that wages are essential to meeting their
employees basic needs. Employers should pay workers for all work
completed and shall pay at least the minimum wage required by law or
the prevailing industry wage, whichever is higher, and shall provide
legally mandated benefits.
Age and Wage Verification
Manual or electronic time cards should be used for hourly workers. For
“piecework” workers, an industry recognized system, capable of audit
verification, should be used.
Employers should provide to workers, for each pay period, a clear and
understandable wage statement that includes days worked, wage or piece
rate earned per day, hours of overtime, bonuses, allowances and a
description of any and all deductions.

We are committed to only working with suppliers that fairly compensate all workers. As
such, we require all suppliers to comply with the following :
Workers must be paid for all work completed. We discourage the practice of using
monetary deductions as a means of enforcing discipline.
Workers must be paid at least the legal minimum wage or the prevailing industry
standard, whichever is greater.
Piece rate workers should also receive at least the legal minimum wage irrespective of their
actual output.
Factory should maintain personnel files and payroll record on every employee.
Workers must be provided with all legal mandated benefits.
All overtime must be indicated on the worker’s time card as well on their payroll record.

04/2008 45 General Principle & Standards - Wages and Benefits


Appendix 2

Time Cards
Manual or electronic time cards must be used for hourly workers. For workers paid on a
“piece rate” basis, all factories must utilize a wage calculation system that is industry
recognized and capable of audit verification.

Individual workers must physically sign or punch themselves in.

Wage Statement
For each pay period, all workers must be provided with a clear and understandable written
wage statement which includes details of the following :

Days worked
Daily wage or piece rate earnings
Overtime hours
Bonuses
Allowances
Any and all deductions

04/2008 46 General Principle & Standards - Wages and Benefits


Appendix 2

Labor Laws
When it is legally required to post labor laws or have the labor law books kept in the factory
for workers’ perusal, they must be prominently posted / kept in the factory.

Best Practices :

To ensure that there is complete transparency and cognizance of all the factories personnel
rules and regulations, suppliers are recommended to :

Maintain a separate written personnel policies covering :


- Wages - Benefits and Reductions
- Vacation and Leave - Regular Working Hours
- Overtime Hours - Overtime Rates
- Personal and Sick Leave - Discipline and Termination
- Grievance Procedure - Harassment and Abuse

Post all personnel policies prominently where workers have easy and comfortable access.
Distribute a written copy of personnel policies to all workers in their native language.
Maintain a written employment agreement with every worker.

04/2008 47 General Principle & Standards - Wages and Benefits


Appendix 2

8. WORK HOURS AND OVERTIME

Work Hours
As part of normal business hours, suppliers’ factories should be working
toward achieving a 60-hour work week on a regular basis. Employees
shall not work more than 72 hours per 6 days or work more than a
maximum total of 14 hours per a continuous 24 hour period and should
limit this to peak periods. Workers shall not be asked or required to
take work home or off premises and must be permitted one full day off
per each seven day week.
Overtime
It is understood that overtime is often required in the manufacturing
process. In addition to compensation for regular hours of work, workers
must be compensated for overtime hours at such a premium rate as
legally required or, in countries where there is no legal standard, at
industry standards. In no event shall this be at a rate less than the
regular hourly rate. Factories shall carry out operations in ways that
limit overtime to a level that ensures productive and humane working
conditions.

Work Hours
Excessively long durations of work can have grave effects on the physical and mental health
of workers, which in turn endangers the health and safety of other workers. Moreover, it also
results in lower productivity and quality at the factory output level. Workers need adequate
time off to meet their social needs and to protect their welfare and that of their families.

While recognizing that flexibility in scheduling and working hours is required in most
manufacturing operations, we require all our factories to carry out operations in a manner
that ensures productive and humane working conditions. As such, all our suppliers must
comply with the following requirements :

All workers must be granted one full day off out of each seven-day week.
Workers must not be required to work in excess of a 60-hour work week on a regularly
scheduled basis.
Workers must not be asked or required to take work home or off premises.
Understand that under peak period of production, excess working hour is required. We
grant a restricted flexibility here. All workers must not be required to work more than
72-hours per 6 days or work more than a maximum total of 14 hours per a continuous 24
hour period. Maximum time covered under peak periods is 4 months.

04/2008 48 General Principle & Standards - Work Hours and Overtime


Appendix 2

Overtime
Workers must be allowed to refuse overtime without any threat of penalty, punishment or
dismissal.
All workers must be compensated for overtime work at a wage rate that meets all legal
requirements or local industry standards. Hourly wage rates for overtime must not be
lower than regular hourly rates.
If authorization is obtained from local government authority which allows the factory to
have employees work in excess of the legal limits, the factory should maintain the original
of this authorization document on site for inspection and verification.

Best Practices :

To counter the practice of forced overtime in factories, suppliers are recommended to adopt
the following preventive measures :

Establish a written overtime policy where workers can refuse overtime requests without a
negative impact on their employment status.
Implement the use of overtime consent forms that require the signed consent of workers.
Formalize a policy to provide workers with advance notice about anticipated periods of
overtime.

04/2008 49 General Principle & Standards - Work Hours and Overtime


Appendix 2

9. COMPLIANCE WITH LAWS

All standards set forth in this Code of Conduct are subject to


compliance with applicable local law. All vendors shall operate in full
compliance with the laws of their respective country of manufacture. If
any standard set forth in this Code of Conduct is, in the vendor’s
judgment, deemed to violate an applicable local law it must advice
Macy’s promptly in writing.

All the standards specified in our Code of Conduct are subject to compliance with any / all
local laws and all suppliers must operate in full compliance with the laws of the country of
manufacture. In addition, our suppliers are required to advise us in writing of any situations
where standards in our Code of Conduct are thought to violate applicable local law.

04/2008 50 General Principle & Standards – Compliance with Laws


Appendix 2

10. ENVIRONMENT

Macy’s will favor those suppliers that share its commitment to preserving
our environment by reducing, re-using and recycling. Macy’s encourages
suppliers to reduce excess packaging and to use non-toxic,
environmentally friendly materials whenever possible. Macy’s policy
specifically prohibits the use of ozone-depleting substances and requires
compliance with the United States Endangered Species Act of 1973. Our
vendors are responsible for continuing compliance with these laws,
including any modifications and amendments, without notice by Macy’s
of such amendment or modification.

The best thing all of us can do to help the environment is simply not to be wasteful.
Macy’s has had a significant corporate focus on protecting the environment through
energy reduction, renewable energy, recycling and waste stream reduction. Macy’s is also
committed to identifying fashion that is eco-friendly. We will be looking to our suppliers
to help us purchase more environmentally friendly products for internal consumption as
well as eco-friendly merchandise.
We also require all suppliers to comply with U.S. laws as relate to the use of ozone-
depleting substances (such as Halons and Chlorofluorhydrocarbons) and the U.S.
Endangered Species Act of 1973.
The Endangered Species Act of 1973 is an internationally recognized law which is aimed
at the protection of any species (fish, wildlife and plants) that is deemed to be in danger
of extinction. The purpose of the Act is to provide a means whereby the ecosystems
upon which endangered species and threatened species depend may be conserved.

04/2008 51 General Principle & Standards – Environment


Appendix 2

11. SUBCONTRACTORS

All subcontractors must be disclosed to Macy’s prior to production, and


all subcontractors and facilities must be pre-approved by Macy’s. Any
subcontractor retained by a Macy’s supplier must be in compliance with
this Code of Conduct and each of Macy’s suppliers is responsible for
ensuring its subcontractor’s compliance.

In order to exercise control and management over all manufacturing facilities producing our
products, we do not allow our designated suppliers to subcontract the production of all
and/or part of our orders to subcontractors without prior notification to us. Once notified,
the subcontracting facility must be evaluated and approved by us. It is the responsibility of
the designated supplier to ensure that the subcontractor they have retained is in compliance
with our Code of Conduct.

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Appendix 2

12. CODE OF CONDUCT POSTER

A copy of the Vendor / Supplier Code of Conduct, translated into the


native languages of the workforce, should be prominently displayed
within each facility where Macy’s merchandise is being manufactured.

It is a mandatory requirement for all MMG manufacturers to display our Code of Conduct
Poster in a prominent location in their factory.

Macy’s will supply each manufacturer with a poster(s) in the native language(s) of their work
force. Currently, we maintain an inventory of posters in the following 36 languages :

Albanian French Lao Slovak


Arabic German Macedonian Spanish
Bengali Hebrew Malay Tagalog
Bulgarian Hindi Marathi Tamil
Cambodian Indonesia Nepali Telugu
Chinese (Simplified) Italian Polish Thai
Chinese (Traditional) Japanese Portuguese Turkish
Czech Kanada Romanian Urdu
English Korean Sinhalese Vietnamese

To ensure workers are well aware of our minimum requirements, suppliers should :

Frame and / or laminate our posters for added protection to show its importance.
Mount the poster in an area in the factory which is of central access to all workers, such
as
- near the notice bulletin board.
- near the area where workers must sign / clock in-and-out for duty.

04/2008 53 General Principle & Standards - Code of Conduct Poster

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