Code of Conduct

CODE PRINCIPAL

Our mission at Fox Head, Inc. (“Fox”) is to operate in compliance with all laws, rules and regulations relating to various licenses, labor, wages, worker health and safety, environment and all other relevant laws. Fox and its supply chain (collectively, “Facilities”) shall treat all workers with respect, dignity and fairness. The Facilities shall operate in such a way so as to minimize the impact of its processes on the environment. The Facilities shall be committed to put in place an effective system to ensure it conducts business in a socially responsible manner.

The Facilities shall comply with the following code standards:

DISCRIMINATION

  • The Facilities shall not subject any worker to any discrimination in employment, including hiring, salary, benefits, promotion, discipline, termination or retirement, on the basis of gender, race, color, religion, cast, age, disability, sexual orientation, maternity or marital status, nationality, political opinion, union membership or social or ethnic origin.

COERCION

  • The Facilities shall undertake any disciplinary action only in accordance with local law.
  • The Facilities shall treat all workers with respect and dignity. No worker shall be subjected to any physical, psychological, sexual, verbal abuse or harassment.
  • The Facilities shall not resort to corporal punishment, violence or intimidation against any worker.

FORCED LABOR

  • The Facilities shall not use any involuntary or forced labor, whether in the form of prison labor, indentured labor, slave or bonded labor or otherwise.
  • The Facilities shall not require workers to deposit their original identity documents, travel documents, educational certificates or any other such important documents as a condition to employment.
  • The Facilities shall permit any worker to leave the employment after a reasonable or legally required notice.
  • The Facilities shall not hold back any wages or a part thereof in order to exercise pressure on any worker to continue in the employment.
  • Companies recruiting foreign contract workers shall not require any worker to remain in employment for any period of time against his or her will. Foreign Contract Workers shall be given a copy of the contract in a language understood by the worker. The Facilities shall not require the worker to pay any fee to the recruitment agent.

CHILD LABOR

  • The Facilities shall not employ Child Labor. The minimum age for hiring will not be less than 15 years or the legal minimum age whichever is higher.
  • The Facilities shall comply with all local laws applicable to the employment of young workers regarding restrictions on employing for hazardous, unsafe and unhealthy operations, working hours, wages, working conditions and appropriate documentation.
  • The Facilities shall maintain appropriate and reliable age-proof for all workers.
  • The Facilities shall have a written recruitment policy and system to verify the age of a worker.
  • The Facilities shall encourage and support night classes, work-study programs and other educational programs for young workers.

WAGES & BENEFITS

  • The Facilities shall pay at least the legal minimum wage required by local law.
  • The Facilities shall pay the statutory social security/insurance contributions for eligible workers as applicable by local law.
  • Facilities hiring trainee workers shall pay wages to such workers in accordance with local law. In the absence of a relevant law, the trainees shall not be paid less than the legal minimum wage or the prevalent industry wage whichever is higher.
  • Any deductions from the wages shall be strictly in accordance with local law. There shall be no punitive deductions from the wage of any worker.
  • The Facilities shall pay overtime wages as mandated by local law. Hourly rate of wage for overtime must be higher than the ordinary rate of wage.
  • The overtime premium for piece rate workers shall be calculated in accordance with local law. In the absence of a law it should be calculated in a way that meets the legal overtime premium rate meant for fixed rate workers.
  • The Facilities shall maintain a copy of all relevant records relating to contract workers for inspection.
  • The Facilities shall not endeavor, beyond a reasonable level; to employ contract workers, trainees or apprentices in order to avoid payment of certain benefits, which may be granted by local law to regular workers.
  • The Facilities shall provide paid annual leave, holidays and other leaves such as maternity leave, medical leave etc. as prescribed by local law.
  • The Facilities shall pay bonus, pension and retirement benefits to all workers as mandated by local law.
  • The Facilities shall provide an understandable wage statement to every worker for each wage cycle in a form prescribed by local law. The wage statement should indicate at least the days worked, wage or piece rate earned allowances if any, social security/statutory deductions, incentives/bonus and overtime wage if any.

WORKING HOURS

  • The Facilities shall set working hours in compliance with local law.
  • The Facilities shall not require workers to work in excess of 60 hours per week including overtime on a regularly scheduled basis. However, in countries where local law further restricts overtime, the Facilities shall follow local regulation.
  • The Facilities shall comply with local law and regulations, if any, relating to overtime hours/night shifts by female and young workers. The Facilities shall endeavor to take necessary steps for the safety of female workers if required to work overtime or in the night shift.
  • The overtime shall be strictly voluntary. Workers shall have the right to refuse overtime without any threat of punishment in any manner.
  • The workers shall have at least one day off in a week. If due to any business reasons a worker is required to work on a weekly holiday, the Facilities shall allow a compensatory day-off within next three days or as stipulated in local law. In any case, no worker shall be required to work for more than 13 days without being given a day off.
  • The Facilities shall endeavor to improve operations to limit overtime to a reasonable level that ensures healthy, humane and productive working conditions.
  • Nursing mothers shall be permitted reasonable breaks without any deductions to feed their babies if the day-care center is housed within the facility. Pregnant workers should be given reasonable breaks to rest during the day.

SAFETY

  • The Facilities shall comply with all local regulations relating to the health and safety of workers in the workplace as well as in their residential facilities if provided by the employer.
  • The Facilities shall ensure adequate lighting, circulation, ventilation, heating / cooling of the workplace.
  • Adequate protection shall be provided from fire, accidents, toxic materials, chemical spillage, dangerous machinery parts and electrical risks.
  • The workplace shall have clearly marked adequate exits for emergency evacuation of workers. Evacuation routes must be posted in all work areas.
  • All doors must be kept open and aisles, exits, stairs free from any obstruction during working hours to facilitate an emergency evacuation in the event of any accident or fire.
  • All exits, stairwells and sections must have emergency lighting.
  • The workplace shall have adequate fire alarms accessible in all sections/floors in the facility.
  • The Facilities shall train an adequate number of workers in using fire safety equipment such as fire extinguishers. Periodic fire drills must be conducted and duly recorded as per local law or at least once in six months.
  • The workplace shall have adequate number of suitable fire extinguishers in all sections/floors. Fire extinguishers must be inspected periodically and refilled as required.
  • Fire extinguishers shall be at a height where they remain visible and accessible by most workers. The location of fire extinguishers and the area in front of them should be marked with a "yellow box" indicating that it should always be clear of any obstruction.
  • All machinery shall be equipped with suitable operational safety devices. A maintenance log should be maintained recording periodic inspection and service.
  • Workers shall be provided appropriate personal protective equipment - such as gloves, aprons, masks, goggles, earplugs, headgear and rubber boots- free of cost. Workers shall be given necessary training to use the personal protective equipment.

HEALTH & HYGIENE

  • The Facilities shall provide safe drinking water for all workers with adequate access to it throughout the working day.
  • The Facilities shall place an adequate number of unlocked stocked first aid kits which must be accessible to most workers on every floor of the workplace. An adequate number of workers must be trained in basic first aid.
  • The Facilities shall have procedures and facilities such as transport/ambulance to deal with serious injuries that require medical treatment outside the Facilities premises.
  • The workplace shall have adequate number of clean toilets/bathrooms (segregated by sex) for all workers with running water allowing adequate access to them throughout the day.
  • If provided by the Facilities, the canteen shall be kept clean ensuring general hygiene and comfort.
  • The Facilities shall store hazardous substances in safe, secure, separate and ventilated areas.
  • The Facilities shall have procedures to ensure pregnant workers are not required to perform tasks that can be unsafe or unduly strenuous for them.

HOUSING / DORMITORIES

  • Housing facilities, if provided by the Facilities, shall meet all local laws and regulations related to security, health & hygiene, safety from fire, electrical, mechanical and structural accidents.
  • The housing quarters shall have adequate living space for each worker, personal storage space, proper ventilation, room cooling/heating systems/fans, adequate lighting, potable water, cooking facilities, basic first aid, necessary firefighting equipment, emergency lights, emergency exits, clean toilets with running water and individual beds. Accommodations must be segregated by sex. The residents should have reasonable freedom to come and go.

FREEDOM OF ASSOCIATION

  • The Facilities shall recognize and respect the right of workers to lawfully form and join trade unions or associations of their own choosing and to bargain collectively.
  • The Facilities shall facilitate a parallel independent mechanism to enable workers to organize and bargain collectively if local law prohibits formal trade unions.
  • The Facilities shall not subject any worker to any discrimination, victimization, intimidation, penalty or any other threat to restrict and interfere with their right to associate. The Facilities shall not directly or indirectly force any worker to join or not to join a particular union. The worker shall have a free and independent choice to join or not to join a particular union.

ENVIRONMENT PROTECTION

  • The Facilities shall comply with all local environmental rules, laws and regulations.
  • In the absence of a suitable local law, the Facilities must endeavor to meet with relevant international standards.
  • The Facilities shall have a disaster-management plan to deal with any environmental emergency.
  • The Facilities should dispose of all waste material, by-products and hazardous pollutants in an environmentally responsible manner. The Facilities should minimize waste and maximize recycling to protect and conserve the natural environment.
  • The Facilities shall store all hazardous material and chemicals in a well-ventilated safe place away from the work area with appropriate labeling. The Facilities should post a list of all hazardous substance used in the facility/workplace mentioning applicable first aid for the knowledge of workers.
  • If applicable due to the nature of processes used, the Facilities should have a wastewater treatment plant conforming to applicable national or international standards.

WOMEN’S, DISABLED, ETHNIC MINORITIES AND U.S. VETERANS RIGHTS

  • All Employers will ensure that workers who are women, disabled, or an ethnic minority receive equal treatment in all aspects of employment. All U.S. employers will ensure that veterans receive equal treatment in all aspects of employment.

SUB-CONTRACTING

  • Fox does not permit unapproved sub-contracting under any circumstances. In the event that a sub-contractor is approved by Fox in writing, the facility hiring the sub-contractor must cause such sub-contractor to adhere to and comply with the Code Of Conduct principals. Additionally, the facility must supply Fox, in writing, with the name and location of the sub-contractor. All salesman sample and bulk production orders must be placed within facilities that have been pre-approved by Fox.