1.0

Wesmo’s Code of Conduct summarizes the basic requirements concerning working conditions that must be satisfied by each Factory and/or Supplier for every location. Wesmo reserves the right to change and supplement the Code of Conduct at any time.

Wesmo and Wesmo’s Suppliers shall familiarize their managers with the Code of Conduct and display it, translated in the local language, at each of their facilities in a place readily visible and accessible to the managers. Suppliers of Wesmo are required to provide Wesmo access to every facility to conduct scheduled and unscheduled inspections for the purpose of ensuring compliance with this Code of Conduct. During inspections, Wesmo shall have the right to review all employee related books and files maintained by Supplier and to interview managers and workers.

2.0

Wesmo and/or Wesmo’s Suppliers shall not use child labor. According to the International Labor Organizations’ Convention 138 (1973): The minimum age….should not be less than the age of compulsory schooling and, in any case, shall not be less than 15 years. If the country or province has a more restrictive definition of child labor, then

Wesmo will not run a factory and/or will not do business with Suppliers in violation of that kind of definition. Wesmo and/or Wesmo’s Suppliers must verify the age of their workers and maintain copies of their workers’ proof of age. Wesmo and/or Wesmo’s Suppliers must follow all applicable laws and regulations regarding working hours and conditions for minors.

3.0

Wesmo and/or Wesmo’s Suppliers shall not use involuntary labor. “Involuntary Labor” is defined as work or service which is extracted from any person under threat or penalty for its non-performance and for which the worker does not offer himself or herself voluntarily, and includes all manner of prison, bonded, indentured and forced labor.

4.0

Wesmo and/or Wesmo’s Suppliers shall comply with the laws addressing human trafficking and slavery of the country or province where the company is located. For purposes of this Code of Conduct, the operative standard for defining “Human Trafficking” is taken from the U.N. Convent against Transnational Organized Crime (Palermo Protocol): “…. the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery or practices similar to slavery, or servitude;………”

Wesmo and/or Wesmo’s Suppliers shall certify that they have implemented procedures to manage all aspects of the purchase and production chains to ensure they comply with laws on slavery and human trafficking. Workers must be allowed to maintain control over their identity documents.

5.0

Wesmo and/or Wesmo’s Suppliers must implement hiring practices that accurately verify workers’ age and legal right to work in the country or province prior to employment. All terms and conditions of employment include, but not limited to, hiring, pay, training, promotion, termination, and retirement must be based on an individual’s
ability and willingness to do the job. Both, Wesmo and Wesmo’s Suppliers must have internal controls validating the legal right of foreign workers to work in the country or province. Every foreign worker must have a valid work permit and be in the country or province lawfully. Work permits as well as copies of government issued identification documents must be maintained in the personnel files of workers.

Wesmo and/or Wesmo’s Suppliers must shall employ workers solely on the basis of their ability to do the job and shall not discriminate on the basis of age, gender, racial characteristics, maternity or marital status, nationality or cultural, religious or personal beliefs or otherwise in relation to hiring, wages, benefits, termination or retirement. Wesmo and/or its Suppliers shall treat all workers with respect and dignity. They shall not use corporal punishment or any other form of physical or psychological coercion or intimidation against workers.

6.0

Wesmo and/or Wesmo’s Suppliers shall provide workers with a clean, safe and healthy workplace in compliance with all applicable laws and regulations. The work environment must be safe and sanitary to ensure there are no unreasonable risks to the health and safety of all workers. Wesmo and/or Wesmo’s Suppliers must implement procedures and safeguards to prevent accidents and injuries to workers; procedures and safeguards include, but are not limited to, inspections of buildings, machinery, and fire extinguishers. Regular and recorded health and safety training shall be provided for all new or reasigned workers and management. Aisles, exits, emergency exits, stairwells, etc. must be kept clear and unblocked at all times. The workplaces must provide adequate lighting and ventilation. Wesmo and/or Wesmo’s Suppliers must maintain chemical safety ensuring appropriate chemical storage, eye wash stations, and personal protective equipment for workers. They shall comply with these provisions in accordance with their specific industry conditions and related hazards.

7.0

Wesmo and/or Wesmo’s Suppliers should ensure that every manufacturing facility complies with environmental laws, including all laws related to waste disposal, air emissions, discharges, toxic substances and hazardous waste disposal. They must validate that all input materials and components were obtained from permissible harvests consistent with international treaties and protocols in addition to local laws and regulations.

Wesmo and/or Wesmo’s Suppliers shall comply with all applicable laws and regulations in respect of protecting the environment and maintain procedures for notifying local authorities in the event of an environmental accident resulting from their operations. In addition to meeting specific laws and regulations such as acquiring the necessary permits and approvals relating to waste disposal, air emissions, wastewater discharge, water use, energy conservation, hazardous substances, environmental impact access, land use, and noise pollution, Wesmo and/or Wesmo’s Suppliers should have an awareness of significant environmental aspects or impacts, both positive and negative.

8.0

Wesmo and/or Wesmo’s Suppliers shall provide wages and benefits that comply with all applicable laws and regulations or match the prevailing local industry rates, whichever is higher. Overtime pay shall be calculated at the legally required rate, regardless of whether workers are compensated hourly or by piece rate. Workers must be compensated in accordance with the law and where applicable with contractual agreements. They must be provided with written and understandable details regarding their employment and compensation.

9.0

Wesmo and/or Wesmo’s Suppliers shall not require workers to work, including overtime, more than 60 hours per week or more than any maximum number of hours per week established by applicable laws and regualtions, whichever is less. They shall guarantee that workers receive at least one day off during each seven day period.

10.0

Wesmo and/or Wesmo’s Suppliers shall respect the right of workers to take advantage of any laws relating to employee management relations. Workers must be able to join or form trade unions consistent with laws and regulations. Wesmo’s and/or Wesmo’s Supplier’s management must not prevent workers from exercising their rights and must not discriminate against worker representatives and union members due to their membership or affiliation with a trade union.

11.0

Legal Requirements. Wesmo and/or Wesmo’s Suppliers shall comply with all legal requirements applicable to the conduct of their business, including those set out above.