IMAGE SOURCE is committed to operating our business and sourcing our products in an ethical and responsible manner. We have adopted a Commitment to Ethical and Responsible Conduct which is recognized by the promotional products industry and covers, among other things, product safety, workplace standards and community focus that exist throughout our global sourcing efforts, production facilities and operating processes.

IMAGE SOURCE believes strongly in providing the safest and highest quality products by focusing on the following key Pillars of Responsible Sourcing:

• Product Quality;
• Product Safety and Compliance;
• Social Responsibility;
• Environmental Stewardship; and
• Supply-Chain Security and Import/Export Compliance

IMAGE SOURCE acknowledges the need to adhere to established and applicable compliance standards, rules, and regulations for our products. We produce compliant products to promote safety, quality and reliability and we implement industry-approved testing procedures to verify compliance, safety and quality of our products to provide you with greater confidence and protection.

We strive for compliance with all applicable laws and regulations in the United States, including but not limited to those enforced by CPSC and FDA, as well as California Proposition 65:

1. We use only reputable CPSC-accredited 3rd party laboratories for all required testing.
2. As applicable, we will affix Children’s Product tracking labels to toys and children’s products.

We will conduct all mandated testing and certification for General Use Products or Children’s Products:

1. The reports will provide test results in English and in a manner that allows for identification of the product tested by lot and batch, the test(s) conducted, the date of test(s) and testing lab.
2. We will provide copies of all test reports to Customers as requested.

We will cooperate with Customer’s efforts to audit our facilities’ compliance as required.

IMAGE SOURCE has an operating philosophy to exceed the expectations of our Clients each and every day. IMAGE SOURCE has established standards for the integrity of our products and processes that demonstrate we are committed to respecting the rights of Individuals while protecting our communities and environment.

IMAGE SOURCE is also dedicated to “Helping Create Positive Client Experiences” by complying with the applicable laws of each community and to conduct business in an ethical and responsible manner.

IMAGE SOURCE Promotional Products believes we are guided by the highest ethical expectations of our Clients. In addition to our standards for the quality and safety of the products we sell, we are also committed to assuring that our manufacturing processes respect the rights of individuals who help make our products while also protecting the environment in which they work.

IMAGE SOURCE will comply with all applicable laws, and we will conduct business in an ethical, responsible manner. We expect the same commitment from vendors that provides IMAGE SOURCE products as a manufacturer, importer or supplier. We also expect our suppliers to maintain procedures to ensure continual compliance and open their factories and records for audits by IMAGE SOURCE’s staff or qualified 3rd party organizations.

IMAGE SOURCE has adopted the following Code of Conduct:

Legal Compliance

All laws and regulations in the country of business and manufacture shall be complied with; this includes legislation on product quality, product safety, labor and employment, health and safety, supply chain security, and the environment.

Product Safety

We will comply with all applicable laws and regulations regarding safety of products we sell. We will meet applicable recognized voluntary industry standards for our products and processes.

No Abuse of Labor

We will not use any form of forced labor, including indentured, prison, bonded or slave labor. We will not use physical or verbal harassment or abuse to discipline employees.

No Child Labor

We will not use child labor. We will comply with all minimum age provisions of applicable laws and regulations.

Freedom of Association

We respect the rights of employees to associate or organize without fear of reprisal or interference. If employees are represented by an organization recognized under law, we respect the right to bargain collectively.

No Discrimination

We will not discriminate in hiring and employment practices on the basis of age, nationality, race, religion, social or ethnic orientation, gender, sexual orientation or disability.

Hours and Wages

We will comply with all applicable wage, work hours, hiring, benefits, and overtime laws and regulations. In the absence of law in a particular location relating to product safety, labor, employment, environment or working conditions, the spirit and intent of these policies shall be met.

Workplace Conditions

We will provide a safe, healthy and secure workplace. We will abide by all applicable laws and regulations for safety and health. Proper sanitation, lighting, ventilation and fire safety protection will be provided.

Environment

We abide by all applicable environmental laws and regulations. We will manage our environmental footprint to minimize the adverse impact on the environment. We will manage our energy, water and waste systems for maximum efficiency and minimal adverse impact on the environment.

Subcontractors and Sources

We require all businesses that support our business as subcontractors, manufacturers or sources of goods to comply with all of the same policies stated in our Code of Conduct policy. All subcontractors and vendors are required to comply with all applicable and national laws. We expect those businesses to develop and implement internal business procedures to ensure compliance with our policy.

Communications

Employers shall communicate this Code to management and employees orally and in writing. This Code shall be posted in a place that is accessible by all employees on a daily basis in a language or multiple languages so that this Code is understood by all employees.

IMAGE SOURCE’s adoption of this Code of Conduct demonstrates our sincere commitment to the business principles stated and to the promotional products industry in total. It is our guide to conducting our business decisions and relationships.

The CPSIA was signed into law August 14, 2008 to increase toy safety standards and mandate third party testing of children’s products and toys and other consumer products. This federal law expanded current CPSC (Consumer Products Safety Commission) authority (see: www.cpsc.gov ) and created responsibilities for those who make, distribute and sell consumer products including items intended for children’s usage.

IMAGE SOURCE products meet current CPSIA standards and guidelines so that Clients can be confident they are receiving the safest products available in the marketplace. IMAGE SOURCE’s product offerings are primarily designed for general use by adults and are not intended for children age 12 or younger unless specifically stated in product descriptions. However, a company and/or their client, by ordering a specific advertising imprint, may render a product as targeting children by doing the following:

• Utilizing marketing art. cartoons, content and/or advertising images specifically targeting children; or
• Normal consumer recognition of a product changes, as it was originally intended, to reach the children’s marketplace because of its imprint, packaging or method of sale or distribution;

As defined under the CPSIA, a “children’s product” means a consumer item designed or intended primarily for children 12 years of age or younger. In determining whether a consumer product is primarily intended for a child, the following factors will be considered:

• A statement by the manufacturer about the intended use of the product, including a label on the product if such statement is reasonable.
• Whether the product is represented in its packaging, display, promotion or advertising as appropriate for use by children.
• Whether the product is commonly recognized by consumers as being intended for use by a child.
• Logo and/or imprint are utilized on a product to specifically target children.

IMAGE SOURCE requires tracking labels on all Children’s Products. The CPSIA requires that Children’s Products have permanent labels on the product and its packaging, to the extent practicable, that will determine:

• Location and date of production of the product.
• Whether the product is represented in its packaging, display, promotion or advertising as appropriate for use by children.
• Production information (including batch, run number, or other identifying characteristic).
• Other information needed to determine the specific source of the product.

California’s Safe Drinking Water and Toxic Enforcement Act of 1986, also known as Prop 65, requires a warning notice on products that contain substances and chemicals identified by the State of California to cause cancer or reproductive toxicity. Currently, over 1,000 chemicals are on California’s list of hazardous substances and chemicals and that list can be found at www.oehha.org/prop65 .

In the event a product requires Prop 65 labeling and we are informed by our Client that the order will ship to California, IMAGE SOURCE will label the product free of charge. There are several different formats for the Prop 65 warning label, but IMAGE SOURCE will typically use the following “short form” label that has been approved by the State of California and its Office of Environmental Health Hazard Assessment to cover risks of exposure to substances that can cause cancer and reproductive harm:

If any of our customers have specific Prop 65 labeling requirements, please advise us and we will use our best efforts to accommodate you.