Code of Conduct

Boxercraft, Inc. Code of Conduct (the “COC”) helps to ensure that Boxercraft, Inc. and its affiliates and subsidiaries do business with reputable business  associates committed to Boxercraft’s ethical standards and business practices. The COC applies to the people and companies that do business with  Boxercraft. Boxercraft expects its Suppliers to act in a manner compatible with standards that contribute to Boxercraft’s outstanding reputation.  Boxercraft expects that its global Suppliers conform to the following: 

Business Integrity  

Ethics:  

Boxercraft, Inc. will conduct its business in an ethical manner following, but not limited to, standards of honesty, integrity, trustworthiness, and respect  for the unique intrinsic value of each human being. Suppliers must comply with all applicable laws and regulations in their country of operation. Also,  suppliers must not directly or indirectly give or receive improper business advantage via the giving or receiving anything of value in exchange for  preferential treatment. 

Social and Working Conditions  

Child Labor:  

Boxercraft, Inc. is committed to the elimination of the “worst forms of child labor,” as defined by International Labor Organization (ILO) Convention 138  & 182, from its supply chain. Boxercraft shall not employ any person at an age younger than 16 (or 15 where consistent with International Labor  Organization practices for developing countries, the law of the country of manufacture allow such exception). We expect our suppliers to support and  participate in industry efforts aimed at the elimination of such practices wherever they exist in the supply chain. Children should not carry heavy loads  that harm their physical development. Trafficking of children or forcing children to work are included among the Worst Forms of Child Labor (WFCL). 

Forced Labor: 

Boxercraft and its suppliers must not utilize or benefit in any way from forced or compulsory labor, nor utilize factories or subcontractors that force  unpaid labor. The use of official prison rehabilitation programs is not a breach of the Code. The recruitment, transportation, transfer, harboring or receipt  of persons, by means of the threat or use of force, coercion or other means, for the purpose of exploiting them is prohibited.  

Harassment or Abuse:  

Every employee shall be treated with dignity and respect. No employee shall be subject to any physical, sexual, psychological or verbal harassment of  abuse. Boxercraft, Inc. will not use or tolerate any form of corporal punishment.  

Health and Safety:  

Boxercraft, Inc. shall provide employees with a safe and healthy working environment for all employees that includes appropriate controls, safety  procedures, preventative maintenance, and protective equipment. Practices must comply with all relevant local and national laws, codes and regulations 

Homework: 

Boxercraft, Inc. will ensure that working hours, overtime compensation, and child labor requirements and laws are followed for persons working  partially or fully from home.  

Non-Discrimination:  

Hiring and employment decisions, including those relating to compensation, benefits, promotion, training and development, discipline, and termination,  should be made solely on the basis of the skill, ability, and the performance of workers. Discrimination is not permitted on the basis of race, religion,  gender, political opinion, national extraction, or social origin. In addition, unfair treatment of pregnant employees is prohibited.  

Overtime Compensation:  

In addition to their compensation for regular hours of work, hourly and/or quota-based wage employees shall be compensated for overtime hours at  such a premium rate as is legally required in the country of manufacture or in those countries where such laws do not exist at a rate at least equal to their  regular hourly compensation rate.  

Wages and Benefits:  

Boxercraft, Inc. recognizes shall provide wages at least equal to the applicable legal minimum wage and any associated statutory benefits. If there is no  legal minimum wage, suppliers must ensure that wages are at least comparable to those at similar companies in the local area or to prevailing industry  norms.  

Working Hours and Wages:  

Except in extraordinary business circumstances, hourly and/or quota based wage employees shall 1) not be required to work more than the lesser of (a)  48 hours per week and 12 hours overtime or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture of, where the  laws of such country do not limit the hours of work, the regular work week in such country plus 12 hours overtime; and 2) be entitled to at least one day  off in every seven day period.  

Freedom of Association and Collective Bargaining: 

Boxercraft, Inc. and its suppliers should respect employees’ right to freedom of association including the right to collectively bargain, consistent with  local laws and ensure that all employee relationships are of a voluntary nature. Respect employees’ right to freedom of association (including the right to  collectively bargain). • Suppliers should provide confidential channels for employees to raise grievances, and records should be maintained. 

Environment and Sustainability  

Environmental impact is a key part of Boxercraft’s business practices and the company is committed to supporting sustainable operational and  agricultural production practices. At a minimum, suppliers must fully comply with all local environmental laws and regulations and should strive to  conduct their operations in a way that conserves natural resources.