CODE OF CONDUCT

Introduction 
1.  No forced labour
2.  No child labour   
3.  No discrimination   
4.  Respect for freedom of association and collective bargaining   
5.  No harsh or inhumane treatment
6.  Safe and hygienic working conditions   
7.  Wages are paid
8.  Working hours are not excessive   
9.  Regular employment
10.  Health and Safety
11.  Environmental awareness
12.  Code implementation 

1. No forced labour 

Est Fat shall not allow any form of forced or involuntary. We may not require our employees to make any kind of “deposits”, nor are they entitled to retain employees’ identity documents.
We shall acknowledge the right of our employees to leave their employer after reasonable notice.

2. No child labour 

We shall not employ minors. Inditex defines minors as those persons who have not yet reached their 16th birthday. In cases where local legislation stipulates a higher minimum age, the higher limit shall apply.
Persons with the ages between of 16 and 18 years will be considered young workers. Young workers shall not work during night hours or in hazardous conditions.

3. No discrimination

We shall not apply any type of discriminatory practice with regards the recruitment, compensation, access to training, promotion, termination of the employment agreement or retirement, based on race, caste, creed, nationality, religion, age, physical or mental disability, gender, marital status, sexual orientation and/or union membership or political affiliation.  

4. Respect for freedom of association and collective bargaining 

We shall ensure that their employees, without distinction, have the right of association, union membership and collective bargaining. No retaliation may arise from the exercise of such right and no remuneration or payment whatsoever may be offered to the employees in order to hinder the exercise of such a right. Likewise, they shall adopt an open and collaborative attitude towards the activities of Trade Unions.

Workers’ representatives shall be protected from any type of discrimination and shall be free to carry out their representative functions in their workplace.
Where the rights to Freedom of Association and Collective Bargaining are restricted under law, the appropriate channels to ensure a reasonable and independent exercise of such rights must be designed.

5. No harsh or inhumane treatment 

We shall treat their employees with dignity and respect. Under no circumstances shall physical punishment, sexual or racial harassment, verbal or power abuse or any other form of harassment or intimidation be permitted.  

6. Safe and hygienic working conditions

We shall provide a safe and healthy workplace to their employees, ensuring minimum conditions of light, ventilation, hygiene, fire prevention, safety measures and access to a drinking water supply.
Workers shall have access to clean toilets facilities and drinking water. Where necessary, facilities for food storage shall be provided.
Accommodation, where provided, shall be clean and safe.
We shall take the required steps to prevent accidents and injuries to health of their workers, by minimizing as much as possible the risks inherent to work.
We shall provide their workers with regular training in the matter of health and safety at work. The company shall keep an appropriate record of the training courses done. Likewise, they shall appoint a person in charge of health and safety within the Management, duly authorized and with the appropriate decision taking power.

7. Wages are paid

We shall ensure that wages paid meet at least the minimum legal or collective bargain agreement, should this latter be higher. In any event, wages should always be enough to meet at least the basic needs of workers and their families and any other which might be considered as reasonable additional needs.
We shall not make any withholdings and/or deductions from wages for disciplinary purposes, nor for any reasons other than those provided in the applicable regulations, without the express authorization of workers. Likewise, they shall provide all workers with: written and understandable information about their wages conditions upon their recruitment, and detailed information
We shall also ensure that wages and any other allowances or benefits are paid on time and are rendered in full compliance with all applicable laws and specifically, that payments are made in the manner that best suits the workers. 

8.  Working hours are not excessive

We shall adjust the length of the working day to the provisions of the applicable laws or of the collective bargain agreement applicable for the sector in question, if the latter affords greater protection for the workers.
We shall not require their employees to work, as a rule of thumb, in excess of 48 hours a week and workers shall be granted at least one day off for every 7 calendar day period on average. 
Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate, pursuant to the provisions of the prevailing regulations in force. 

9. Regular employment

We undertake that all the employment formulas they use are part of the applicable local laws. Thus, they shall not impair the rights of workers acknowledged under labour and social security laws and regulations by using schemes that have no real intention to promote regular employment in the framework of regular employment relationships.

10. Health and Safety

We are responsible for to comply with health and safety product standards so that the commercialized products do not entail any risk to customers.
10.1 Building Safety We make employees' safety a priority at all times. No hazardous equipment or unsafe buildings are accepted. 
10.2 Fire Safety Emergency exits on all floors must be clearly marked, well lit and unblocked all the way out of the building. Evacuation through emergency exits must always be possible during working hours. 
Everyone working on the premises, including managers and guards, must be regularly trained in how to act in case of fire or other emergency. Regular evacuation drills for all employees are required; evacuation plans and fire fighting equipment must be in place.
10.3 Accidents and First Aid  The employer must work proactively to avoid accidents causing harm to any employee in the workplace.   
Relevant first aid equipment must be.

11. Environmental awareness

We shall be duly committed at all times to protect the environment and shall comply with the standards and requirements of the applicable local and international Laws and Regulations.
Likewise, they commit to comply with environmental standards established by Inditex including, if applicable, the necessary measures to reduce and compensate such impact in order to apply said standards.  

12. Code implementation 

Manufacturers and suppliers shall implement and maintain programmes to set in motion this Code. They shall appoint a senior member of Management who shall be responsible for the implementation and enforcement of this Code. 
We shall communicate the Code to all employees and those in any way involved.
A copy of the Code, translated into the local language, shall be displayed in accessible locations to all workers.

12.1 Transparency 

We shall carry out our activities in an honest, upright and transparent way, keeping for these purposes an appropriate accounting records system
that facilitates the traceability of their decisions, as a preventive measure versus any type of corruption, bribe and extortion that might arise.
We shall not manipulate or influence their workers, nor shall they forge any files or records in order to alter the verification process regarding compliance with this Code.
We shall neither offer nor accept remuneration of any kind which seeks, or may be perceived to seek, to affect the impartial judgment or the objectivity of such parties appointed by Inditex to carry out inspections and compliance audits in connection with this Code. 

12.2 Reference to national legislation, Conventions and Agreements.  

The provisions of this Code constitute only minimum standards.
Should national regulations or any other applicable Law or any other commitments undertaken or applicable, including collective bargaining agreements, govern the same issue, the provision which offers greater protection for workers shall apply.  

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