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ZIPPO MANUFACTURING COMPANY
CODE OF CONDUCT

Zippo Manufacturing Company and its subsidiaries (collectively “Zippo”) is committed to acting in a social, environmentally friendly and sustainable way, and adheres to the below principles, standards and requirements. Zippo also expects all of its business partners and suppliers (together with Zippo, each a “Company”) to equally strive for these goals and comply with the following:

(1)   Zippo Manufacturing Company is certified to ISO 9001:2015.

(2)   Company will respect human rights and provide healthy and fair working conditions. Where applicable, Company in particular respects the standards set by the International Labor Organization (ILO), laid down in international ILO Conventions, and will comply with national and international regulations.

(3)   Company does not and will not use child labor in the manufacturing, packaging or distribution of any products. The term “Child” refers to a person younger than the local legal minimum age for employment or the age for completing compulsory education, but in no case will any child younger than sixteen (16) years of age be employed in the manufacturing, packaging, or distribution of products. Where employing young persons who do not fall within the definition of “Children”, Company is committed to complying with any laws applicable to such persons.

(4)   Company will only employ persons whose presence is voluntary. Company will not use any forced or involuntary labor, whether prison, bonded, indentured or otherwise, including any forms of modern slavery or human trafficking. Company will employ only persons whose employment is documented, who are free to leave during non-working hours or at the end of their period of work, and who are free to resign.

(5)   Company will not, directly or through third parties acting on its behalf, authorize, offer, promise, or give anything of value, to any person or entity in exchange for the improper performance of any relevant function for Company’s benefit. Company and its employees shall comply with the Zippo Global Anti-Corruption Policy, which is available at https://www.zippo.com/pages/purchasing.

(6)   Company will treat each employee with dignity and respect, and not use corporal punishment, threats of violence, or other forms of physical, sexual, psychological or verbal harassment or abuse. Company strives to maintain for its employees, contractors and guests, a safe and healthy working environment. Company will not tolerate, and will take disciplinary action against, any act of violence (either verbal or physical) committed by or against its employees, contractors or guests.

(7)   In accordance with anti-discrimination law, Company will not discriminate in hiring and employment practices, including salary, benefits, advancement, discipline, termination or retirement, on the basis of race, religion, sex (including pregnancy, child birth, breastfeeding and related medical conditions), age, nationality, social or ethnic origin, sexual orientation, gender identity and expression, genetic information, marital status, political opinion, disabilities, military status or any other status protected by applicable laws or regulations.

(8)   Company will comply, as a minimum, with all applicable wage and hour laws, including minimum wage, overtime, maximum hours and other elements of compensation, and will provide legally mandated benefits. If local laws do not provide for overtime pay, Company agrees to pay at least regular wages for overtime work. Except in extraordinary business circumstances and in any event in compliance with law, it will not require employees to work more than the greater of (a) 48 hours per week and 12 hours overtime or (b) the limits or regular and overtime hours allowed by local law. In addition, except in extraordinary business circumstances and in any event in compliance with law, employees will be entitled to at least one day off in every seven-day period. Where local industry standards are higher than applicable legal requirements, Company will meet the higher standards. More generally, Company will comply with fair employment practice as defined by applicable laws.

(9)   Company will provide employees with a safe and healthy workplace free from recognized hazards in compliance with all applicable environmental health and safety laws ensuring, at a minimum, reasonable access to potable water and sanitary facilities, fire safety, and adequate lighting and ventilation. Company will ensure that the same standards for health and safety are applied in any housing they provide for employees. Company will provide Zippo with any information Zippo may request about manufacturing, packaging and distribution facilities for the products.

(10)   Company will respect the rights of employees to associate, organize and bargain collectively in a lawful and peaceful manner, without penalty or interference, in accordance with applicable laws.

(11)   Company will comply with all applicable environmental laws. Company respects the environment and is committed to environmental protection. Company applies responsible environmental practices like waste prevention, recycling and energy saving and treats natural resources responsibly. This includes, where applicable, the compliance with international standards as to the correct and responsible handling and disposal of hazardous waste (Basel Convention), dealing with persistent organic pollutants (Stockholm POPs Convention) and with mercury (Minamata Convention). Company further applies particular due diligence and duty of care in procuring minerals or other raw materials from conflict-affected and high-risk areas.

(12)   Company takes care to understand the sourcing area of the raw materials used in their products and will not knowingly or negligently provide products that contain raw materials that contribute to human rights abuses. Company will not source raw materials in a negligent manner that would cause harm to the environment.

(13)   Company respects human rights. This includes, where applicable, compliance with the human rights as laid down in the International Covenants of 19 December 1966 on Civil and Political Rights as well as on Economic, Social and Cultural Rights.

(14)   Company will not cause any harmful soil change, water pollution, air pollution, harmful noise emission or excessive water consumption that significantly impairs the natural bases for the preservation and production of food, denies a person access to safe and clean drinking water, makes it difficult for a person to access sanitary facilities or destroys them or that harms the health of a person.

(15)  Company will not unlawfully evict or take land, forests and waters, which secure the livelihood of a person.

(16)  Company will appropriately instruct and control any hire or use of private or public security forces for the protection of the Company`s projects to ensure that such use does not infringe the prohibition of torture and cruel, inhumane or degrading treatment, damage life or limb or impair the right to organize and the freedom of association.

(17)  Company will comply with all applicable laws, including without limitation those pertaining to the manufacture of its products.

(18)  Company will appropriately address compliance with human rights and environmental standards along its own supply chain. Therefore, Company will use its best efforts to ensure that its direct and indirect suppliers comply with the values and standards laid down in this Code of Conduct.

(19)  Zippo and its designated representatives may engage in monitoring activities of its direct and indirect suppliers to confirm compliance with this Code of Conduct, including unannounced on-site inspections of manufacturing, packaging and distribution facilities, and employer-provided house, such inspections to include reviews of books and records in relation to employment matters and private interviews with employees. Company will provide Zippo with access to all sites reasonably requested by Zippo to perform and exercise its rights of inspection hereunder. Company agrees to maintain on-site documentation necessary to demonstrate compliance with this Code of Conduct, which Zippo and its agent may review, make and retain extracts of, to assist the compliance monitoring.

(20)  Company will follow all reasonable and proper procedures for testing to ensure that its products comply with all applicable product safety laws, and will permit Zippo’s designees to inspect testing, manufacturing and quality control records and procedures and to test the products for compliance with product safety and other laws. Company agrees to promptly reimburse Zippo for the actual costs of such testing. Products not manufactured, packaged or distributed in accordance with applicable laws will be deemed unapproved, even if previously approved by Zippo, and will not be shipped unless and until they have been brought into full compliance therewith