FLOOR_STORY ANTI-SLAVERY POLICY

The FLOOR_STORY Ltd Anti-Slavery Policy along with the Supplier Code of Conduct sets out the standards of employment and working conditions that are required throughout FLOOR_STORY’s procurement chains. The standards are intended to meet our beliefs as a company, societal and industry expectations, national legislation and International Labour Organisation (ILO) Conventions.

Employers (as defined below) must treat Workers (as defined below) with basic levels of respect and dignity. We use the standards as a tool to assist us in selecting and retaining business partners who follow business practices consistent with our policies and values. As a set of guiding principles, this FLOOR_STORY Policy also helps our Suppliers identify potential problems so that we can work together to address issues of concern as they arise.

The Policy applies to all organisations that manufacture or procure goods or services for FLOOR_STORY Ltd (“Suppliers”), along with Recruitment Agencies, contractors, Sub-Contractors, Labour Providers and Homeworkers who provide labour resources to the supply chain.

Suppliers must comply with all applicable legislation and also with elements of the Policy where these go beyond what is required by law.

It is the Supplier’s responsibility to ensure that the requirements of this Policy and the Supplier Code of Conduct are met across all of its manufacturing sites and by all Sub-Contractors, Recruitment Agencies and Labour Providers who supply labour resources to these sites. Suppliers must be able to demonstrate to FLOOR_STORY that they have carried out sufficient steps to communicate the standards contained within the Policy, to monitor levels of compliance and to remediate any areas of non- compliance.

The Employer must implement a culture where all Workers feel safe and are respected by their colleagues. The need for a respectful and dignified working environment must be communicated so everyone understands the boundaries of acceptable behaviour. FLOOR_STORY will support Suppliers and their supply chains who disclose difficulties in meeting the requirements of this Policy and seek to work with them to put in place necessary improvements or remediation measures.

FLOOR_STORY ANTI-SLAVERY POLICY

1. TERMS OF EMPLOYMENT

1.1. All Workers’ terms of employment must apply with applicable legislation.

1.2. As a minimum, there must be agreed terms of employment in place between the Worker and the Employer before the Worker commences work.

1.3. Workers must be employed voluntarily and have the freedom to leave their employment.

1.4. Workers must be hired and treated based on their ability to carry out their work and their performance. There must not be any form of discrimination or preferential treatment in the hiring, terms of employment, levels of pay, opportunities and treatment of Workers.

1.5. The Employer must make every effort possible to provide regular, secure employment. The use of temporary contracts or agency labour must not be used as a means of denying Workers their rights or benefits under employment law.

1.6. Apprenticeships and training contracts are encouraged but must be compensated properly and provide adequate levels of training or development. The health, safety and welfare of apprentices employed under such schemes must be safeguarded.

1.7. The responsibility for communicating terms of employment to Migrant and Contract Workers must be well- defined in contracts between the Supplier and recruitment Agencies or Labour Providers. Such contracts must include responsibility for essential induction training.

2. FORCED OR COMPULSORY LABOUR

2.1. The Employer shall not use forced, bonded or involuntary prison labour. All people working within the supply chain must be;

2.1.1. voluntarily recruited and employed;

2.1.2. employed legally with a valid right to work;

2.1.3. free from any form of coercion or threat;

2.1.4. free of any debt to their Employer or Recruitment Agency;

2.1.5. paid in full, on time and at a level that meets or exceeds the applicable minimum wage;

2.1.6. free to leave their employment, given reasonable notice.

2.2. Workers shall be allowed to consult with doctors during working hours.

2.3. No deposit or fee shall be retained for securing work or accommodation, tools, training or personal protective equipment (PPE) or for any other reason.

2.4. There shall be no unreasonable restrictions on Workers’ freedom of movement relating to entering or exiting accommodation or sites of employment.

2.5. Employers, Recruitment Agencies and Labour Providers must not deny Workers access to their identity or immigration documents. If these are held for safe keeping, it must be done voluntarily with the Worker being able to re-claim such documents on request.

2.6. Workers shall not be required to pay Employers’ or agents’ recruitment fees or other related fees for their recruitment and must not be bonded through other loans or fees. If any such fees are found to have been paid by Workers, such fees must be repaid to the Worker by the Employer, including international travel costs.

3. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING

3.1. Workers must be able to communicate openly with their Employer regarding working conditions without fear of reprisal, intimidation or harassment.

3.2. Workers must be free to associate or to join Trade Unions or other organisations that represent them. The Employer must not prevent, or discriminate against, Workers who wish to associate or bargain collectively. The decision whether or not to associate should be made solely by the Workers.

3.3. Employers must not attempt to influence the election or choice of Worker representatives or seek to influence a Worker representative to act in the management’s interest.

3.4. The Employer shall adopt an open attitude towards the organizational activities of Trade Unions. There should be open communication channels between Employers and Workers regarding conditions without threat of reprisal, intimidation or harassment.

3.5. Where local laws restrict freedom of association and Trade Unions, Employers will allow Workers to form Worker groups/committees, if they so choose. There must not be an unequal representation of management to Workers within these groups/committees.

3.6. Where Employers are legally required to consult with Workers, these requirements must be met in full. Formal committees must meet regularly, be adequately attended and operate effectively in the interests of Workers.

3.7. Workers must be allowed to stand as Worker representatives on Trade Unions, works councils or other formal representative groups. They must not be restricted, penalised or discriminated against and must have access to management and co-Workers in order to carry out their representative functions.

3.8. Where Migrant and/or Contract Workers are employed, they must be adequately represented.

3.9. Agreed collective bargaining documentation shall be communicated to Workers and available for the workforce to review.

4. WAGES AND WORKING HOURS

4.1. Wages and benefits

4.1.1. Workers’ wages for a standard working week should meet or exceed national legal standards or the industry benchmark standards, whichever is higher and be at least sufficient to meet basic needs and provide some discretionary income.

4.1.2. Remuneration must comply with agreed contracts, be on time and made in full. Clear written details must be provided to each Worker, showing how the remuneration has been calculated.

4.1.3. Wages shall be paid at least monthly.

4.1.4. The Employer shall provide to the Workers written and understandable information on the wage calculation including:

• hours worked or piece rate if appropriate;
• pay rate;
• gross pay;
• overtime pay;
• itemised deductions; and
• net pay.

4.1.5. Overtime must be offered fairly, paid and managed in accordance with the employment contract and comply with applicable legislation.

4.1.6. Workers must be provided with all benefits they are entitled to under national or local law e.g. paid leave, bonus, sick pay and/or social security payment contributions and provided to the Worker in a written and understandable form.

4.1.7. Where Workers’ basic remuneration is based on their output (piece-rate), the payment must still meet the legal minimum wage. A formal, agreed piece-rate calculation must be in place which ensures that Workers are paid fairly and are able to meet the legal minimum wage, or above, within normal working hours.

4.1.8. The Employer shall pay wages directly to the Worker concerned in legal tender, except as maybe otherwise provided by national laws or regulations or collective agreement arbitration award.

4.2. Deductions

4.2.1. Legally required deductions that entitle Workers to state benefits must be made and passed on by the Employer to the State.

4.2.2. The cost of clothing and protective equipment required to perform work safely must be paid in full by the Employer.

4.2.3. Deductions from wages or any other form of financial penalty must not be used as a disciplinary measure.

4.3. Working hours

4.3.1. The work schedule shall be documented and communicated to the Workers and include the hours at which work begins and ends, as well as where these duties shall be carried out.

4.3.2. Working hours must comply with national laws and collective agreements.

4.3.3. Further to clause 4.3.2, regular working hours shall not exceed 48 hours per week, or exceed 60 hours in any 7-day period (except where covered by clause 4.3.4).

4.3.4. Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances where all of the following are met:

• this is allowed by national law;

• this is allowed by collective agreement, freely negotiated with the Workers’ organisation representing a significant portion of the workforce;

• appropriate safeguards are taken to protect the Workers’ health and safety.

4.3.5. Workers shall be provided with at least one day off in every 7-day period or, where allowed by national law, two days off in every 14-day period.

4.3.6. Overtime must be offered fairly, contracted voluntarily and paid in accordance with applicable legislation. It must not be used to replace regular employment.

4.3.7. Workers must be able to refuse to work overtime without any form of penalty. Workers who refuse overtime must not be denied the opportunity to work overtime in the future.

4.3.8. There must be adequate management systems in place to ensure weekly working hours are controlled within the above limits, except in emergency or unusual situations.

4.3.9. Every Worker shall be entitled to a period of paid holiday leave each year, which is in line with national law.

4.3.10. Every Worker shall be entitled to take reasonable absence from work on the grounds of genuine incapacity through illness, without financial penalty or threat of dismissal. During any such leave the Worker should continue to receive, as a minimum, a reasonable payment to meet basic needs.

5. CHILD LABOUR AND YOUNG WORKERS

5.1. Child Labour

5.1.1. A “Child Worker” is defined as someone who has not reached their 15th birthday, or any higher age specified in local law for completing mandatory schooling or beginning full time work.

5.1.2. However, in strictly limited circumstances, where local law sets the minimum age at 14 years, under ILO convention 138 in accordance with developing country exceptions, the lower will apply.

5.1.3. Child Workers must not be involved at any point in the manufacture or supply of goods to FLOOR_STORY Ltd.

5.1.4. Employers shall develop a system to verify the ages of new Workers including checking original identity documents and cross-referencing with Worker’s photograph.

5.1.5. Employers shall develop a system to prevent borrowed identity documents including spot-checking the availability of the identity documents of existing Workers periodically.

5.1.6. Copies of age records shall be retained in the workplace.

5.2. Young Workers

5.2.1. Where young Workers are employed the Employer must comply with the relevant legal requirements in that region/country. These may include carrying out health and safety risk assessments for young people, restricting working hours and with the relevant contracts and permissions drafted and implemented.

5.3. Preventing Children from Entering Production Areas

Children must not be permitted in production areas at any time, even if they are above the minimum age of employment. This includes the Children of Workers who live in factory accommodation and Children brought to care facilities on site.

Supplier responsibilities

5.3.1. Ensure Children cannot enter production areas;

5.3.2. All Workers and auxiliary Workers e.g. security guards, cleaners understand that Children cannot enter production areas under any circumstance;

5.3.3. Provide safe and adequate supervision of Children living in factory accommodation;

5.3.4. Provide safe and adequate supervision of Children brought to the factory whilst their parents/guardians work. Supplier prevention systems must include:

5.3.5. Full security and monitoring of all site entrances (when facilities are open and/or accessible);

5.3.6. Clear procedures for checking, verifying and recording the identity and age of all visitors;

5.3.7. Security personnel who are fully trained on and understand procedures;

5.3.8. Enforcement of minimum age requirements within production areas.

6. DISCRIMINATION

6.1. Discrimination in any form, based on race, colour, language, nationality, ethnic or social origin, religious belief, political opinion, gender, marital status, disability, property, birth, age, sexual orientation or Trade Union membership shall not be permitted.

6.2. The employment practices and policies of the workplace shall afford all Workers equality of treatment.

6.3. Decisions or practices which are based on unfair discriminatory grounds, rather than on merit, will not be acceptable.

6.4. No job applicant should be unfairly refused employment or offered employment on less favourable terms due to discriminatory practices.

6.5. All Workers should have equal access to jobs, training, promotion and transfer and no one should receive less favourable wages, benefits or access to facilities on grounds of discrimination. The Employer shall develop a policy on discrimination of recruiting, wages, benefits, promotion, training, transfer, termination, retirement or access to facilities.

6.6. Employers are expected to adopt and adhere to a fair disciplinary procedure. No Worker should face or be threatened with discrimination in any form and no Worker should receive disciplinary action or dismissal on grounds of discrimination. Similarly, no Worker should be unfairly selected for redundancy or lay-off based on discrimination by the Employer.

7. RESPECTFUL TREATMENT OF WORKERS

7.1. Corporal punishment, physical, mental or verbal abuse, sexual harassment or other forms of intimidation, harsh, or inhumane treatment shall not be allowed.

7.2. The Employer shall protect their Workers from bullying, verbal or physical harassment, victimisation, discrimination or physical abuse in the workplace, whether from management, from their colleagues or from members of the public.

7.3. The Employer shall develop written grievance and disciplinary procedures for the workplace and communicate these to the Workers.

7.4. A fair disciplinary and grievance procedure shall be established and adhered to in all cases of alleged Worker misconduct or unsatisfactory performance.

7.5. All disciplinary and or grievance measures must be recorded.

7.6. An appeal channel shall be developed and implemented for Workers facing disciplinary action.

7.7. Workers undergoing discipline must have the right to representation by a Trade Union or Worker representative and to a fair appeal.

7.8. Workers who raise grievances must not be penalised or intimidated.