1.

Introduction
This Due Diligence Manual outlines the procedures for PNG(BD)Ltd. (Express) to identify,
prevent, mitigate, and account for actual and potential adverse impacts arising from its
operations, throughout its supply chain, and in accordance with the OECD Guidelines for
Multinational Enterprises (MNE Guidelines) and the Due Diligence Guidance for Responsible
Business Conduct.

2. Policy and Commitment

2.1 Due Diligence Policy:
PNG(BD)Ltd. is committed to conducting its business with respect for human rights, labor
standards, the environment, and ethical business practices. This Due Diligence Manual outlines
the company's commitment to implementing the OECD Due Diligence Guidance and integrating
responsible business conduct throughout its operations and supply chain.
2.2 Management Support:
The Board of Directors and senior management of Express endorse this Due Diligence Manual
and are committed to providing the necessary resources and support for its effective
implementation.

3. Integration
3.1 Scope of Due Diligence:
This Due Diligence Manual applies to all activities of PNG(BD)Ltd., including:
• Garment washing and dyeing processes
• Chemical sourcing and management
• Wastewater treatment and disposal
• Energy consumption and waste generation
• Labor practices within the company and throughout the supply chain
3.2 Risk Assessment:
PNG(BD)Ltd. will conduct regular risk assessments to identify potential adverse impacts in the
following areas:
• Human Rights: Forced labor, child labor, discrimination, working conditions, freedom of
association.
• Labor Standards: Wages, working hours, occupational health and safety, social security.
• Environment: Water pollution, air pollution, hazardous waste management, resource
depletion.
• Business Ethics: Bribery, corruption, anti-competitive practices, responsible sourcing.
3.3 Integration with Existing Systems:
The Due Diligence Management System (DDMS) will be integrated with existing management
systems, such as:
• Environmental Management System (EMS)
• Health and Safety Management System (HSMS)
• Human Resources Management System (HRMS)
• Procurement policies and procedures

4. Implementation
4.1 Due Diligence Procedures:
4.1.1 Identification:
• Stakeholder Mapping: Identify relevant stakeholders like workers, communities,
suppliers, customers, and government agencies.
• Supply Chain Mapping: Map the supply chain to identify high-risk areas and
subcontractors.
• Impact Assessment: Conduct regular assessments to identify potential and actual adverse
impacts in the focus areas mentioned above.
4.1.2 Prevention:
• Develop and implement policies and procedures:
o Human rights policy
o Labor standards policy
o Environmental policy
o Anti-corruption policy
o Sustainable sourcing policy
• Training and awareness programs: Train employees on responsible business conduct
practices and the DDMS.
• Management of chemicals: Implement responsible chemical management practices to
minimize environmental impact.
• Wastewater treatment: Ensure effective wastewater treatment systems to comply with
regulations and minimize water pollution.
• Energy efficiency: Implement measures to reduce energy consumption and greenhouse
gas emissions.
4.1.3 Mitigation:
• Grievance Mechanism: Establish a transparent and accessible grievance mechanism for
stakeholders to raise concerns.
• Remediation: Develop and implement procedures to address any identified adverse
impacts, including providing remedy to affected stakeholders.
4.1.4 Monitoring and Evaluation:
• Monitor the effectiveness of the DDMS: Regularly review the implementation of the
DDMS and measure its impact on identified risks.
• Conduct audits: Conduct internal and/or external audits to assess the effectiveness of the
DDMS.
4.1.5 Documentation:
• Maintain comprehensive documentation of due diligence activities, assessments, and
findings.

5. Stakeholder Engagement
• Establish open communication channels: Maintain open communication with
stakeholders through regular meetings, reports, and other engagement mechanisms.
• Address stakeholder concerns: Respond promptly and transparently to stakeholder
concerns raised through the grievance mechanism.

6. Reporting and Accountability

• Public reporting: Publish an annual sustainability report outlining the implementation of
the DDMS and its progress on identified risks.
• Management accountability: Integrate DDMS performance into management
performance evaluations.
7. Training and Awareness
• Conduct regular training for all employees on the DDMS, responsible business conduct
practices, and relevant policies and procedures.
• Raise awareness among suppliers and business partners about Express's commitment to
responsible business conduct and encourage them to implement similar practices.

8. Continuous Improvement
• Regularly review and update the DDMS based on lessons learned, emerging risks, and
changes in the operating context.
• Stay informed about evolving OECD guidelines and best practices for due diligence
implementation.

9. Conclusion
By implementing this Due Diligence Manual, PNG(BD)Ltd. aims to demonstrate its
commitment to responsible business.