I. Introduction

Corporate Couture ("the Company") is committed to conducting business in an ethical, legal, and socially responsible manner. This Supplier Code of Conduct ("the Code") sets forth the Company's expectations and requirements for all of its suppliers, vendors, contractors, and other third-party business partners (collectively, "Suppliers") with respect to compliance with applicable laws and regulations, as well as adherence to the highest standards of business ethics and integrity.

The Code serves as a guide for Suppliers to understand and meet the Company's expectations. Suppliers are required to comply with the principles and standards outlined in this Code, and to ensure that their employees, subcontractors, and agents also adhere to these requirements. Failure to comply with this Code may result in the termination of the Company's business relationship with the Supplier.

II. Compliance with Laws and Regulations

Suppliers must comply with all applicable laws, rules, and regulations in the countries and jurisdictions in which they operate. This includes, but is not limited to, laws and regulations related to:

A. Consumer Product Safety

1. The Consumer Product Safety Act (CPSA)
2. The Federal Hazardous Substances Act (FHSA)
3. The Flammable Fabrics Act (FFA)
4. The Poison Prevention Packaging Act (PPPA)

B. Environmental Protection

1. The Clean Air Act (CAA)
2. The Clean Water Act (CWA)
3. The Resource Conservation and Recovery Act (RCRA)
4. All applicable state and local environmental laws and regulations

C. Labor and Employment

1. The Fair Labor Standards Act (FLSA)
2. The Occupational Safety and Health Act (OSHA)
3. The National Labor Relations Act (NLRA)
4. All applicable state and local labor and employment laws

D. Anti-Corruption and Anti-Bribery

1. The Foreign Corrupt Practices Act (FCPA)
2. The UK Bribery Act
3. All applicable anti-corruption and anti-bribery laws and regulations

E. Jurisdiction-Specific Requirements

Suppliers must comply with all applicable jurisdiction-specific legal and regulatory requirements that may apply to the Company's Supplier relationships. The Company will provide Suppliers with any additional jurisdiction-specific requirements as necessary.

Suppliers must maintain all necessary licenses, permits, and registrations required to conduct business and must promptly notify the Company of any actual or potential non-compliance with applicable laws or regulations.

III. Ethical Business Practices

A. Conflicts of Interest

Suppliers must avoid any conflicts of interest or situations that may appear to present a conflict of interest in their dealings with the Company. Suppliers shall disclose to the Company any actual or potential conflicts of interest, including any familial, financial, or other relationships with the Company's employees or other stakeholders.

B. Anti-Corruption and Anti-Bribery

Suppliers shall not engage in any form of corruption, extortion, or bribery, whether direct or indirect, in order to obtain or retain business or secure any other improper advantage. Suppliers must comply with all applicable anti-corruption and anti-bribery laws and regulations.

C. Fair Competition

Suppliers shall compete fairly and honestly, and shall not engage in any anti-competitive practices, such as price fixing, bid rigging, or market allocation, in violation of applicable antitrust and competition laws.

D. Confidentiality and Data Protection

Suppliers shall protect the confidentiality of all information and data provided by the Company, and shall not use or disclose such information and data for any purpose other than to fulfill their obligations under the supply agreement. Suppliers must also comply with all applicable data privacy and security laws and regulations, including but not limited to:

1. The General Data Protection Regulation (GDPR)
2. The California Consumer Privacy Act (CCPA)
3. Any other applicable data protection laws

Suppliers shall implement appropriate technical and organizational measures to ensure the security of the Company's data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

IV. Environmental Responsibility

A. Environmental Compliance

Suppliers shall comply with all applicable environmental laws and regulations, including those related to waste disposal, emissions, and the use of hazardous materials.

B. Sustainability and Resource Efficiency

Suppliers are encouraged to implement sustainable business practices and to continually seek ways to reduce their environmental impact, such as by:

1. Minimizing waste and implementing recycling programs
2. Conserving energy and water
3. Using renewable and recyclable materials
4. Reducing greenhouse gas emissions
5. Implementing environmentally friendly packaging solutions

C. Environmental Management Systems

Suppliers are encouraged to implement and maintain an environmental management system (e.g., ISO 14001 or equivalent) to systematically manage and improve their environmental performance.

V. Labor and Human Rights

A. Child Labor and Forced Labor

Suppliers shall not use child labor or any form of forced, bonded, or compulsory labor, and shall comply with all applicable laws and regulations regarding the employment of minors. Suppliers must have robust age verification procedures in place to ensure compliance with minimum age requirements.

B. Wages, Benefits, and Working Hours

Suppliers shall comply with all applicable laws and regulations regarding minimum wages, overtime compensation, and legally mandated benefits. Suppliers shall also ensure that working hours do not exceed the maximum set by applicable laws and regulations. Suppliers shall maintain accurate and complete records of employees' working hours and wages.

C. Freedom of Association and Collective Bargaining

Suppliers shall respect the rights of workers to freedom of association and collective bargaining, in accordance with applicable laws and regulations. Suppliers shall not interfere with, obstruct, or prevent legitimate worker associations and collective bargaining activities.

D. Discrimination and Harassment

Suppliers shall not discriminate against or harass any employee or job applicant on the basis of race, color, religion, national origin, sex, sexual orientation, gender identity, age, disability, or any other characteristic protected by applicable law. Suppliers shall maintain a workplace free from harassment, intimidation, and abuse.

E. Diversity and Inclusion

Suppliers are encouraged to promote diversity and inclusion within their own organizations and supply chains. This includes:

1. Implementing diversity and inclusion policies and programs
2. Providing equal opportunities for employment and advancement
3. Fostering an inclusive work environment that values and respects differences

VI. Health and Safety

A. Workplace Safety

Suppliers shall provide a safe and healthy work environment for all their employees and shall comply with all applicable health and safety laws and regulations. This includes:

1. Conducting regular risk assessments and implementing appropriate control measures
2. Providing necessary personal protective equipment (PPE) at no cost to employees
3. Ensuring proper maintenance of equipment and facilities
4. Implementing safety management systems (e.g., ISO 45001 or equivalent)

B. Emergency Preparedness and Response

Suppliers shall have emergency plans and response procedures in place to address potential emergencies and accidents, and shall provide appropriate training to their employees. This includes:

1. Developing and maintaining emergency response plans
2. Conducting regular emergency drills and exercises
3. Providing clear evacuation procedures and routes
4. Ensuring the availability of first aid supplies and trained personnel

C. Occupational Injury and Illness

Suppliers shall have systems in place to prevent, manage, track, and report occupational injury and illness in accordance with applicable laws and regulations. This includes:

1. Implementing procedures for reporting and investigating incidents
2. Providing appropriate medical treatment and support for injured or ill workers
3. Analyzing incident data to identify trends and implement preventive measures

VII. Supply Chain Transparency and Traceability

A. Supply Chain Mapping

Suppliers shall maintain and provide, upon request, accurate and up-to-date information on their supply chains, including:

1. Names and locations of sub-suppliers and sub-contractors
2. Sources of raw materials and components
3. Manufacturing and processing facilities

Suppliers are responsible for providing all product testing documentation. Products must be tested and pass for any banned contaminants, as well as comply with all California product laws, including but not limited to Proposition 65. This includes requirements for product composition, packaging, and labeling.

B. Due Diligence

Suppliers shall conduct appropriate due diligence on their own suppliers and sub-contractors to ensure compliance with this Code and applicable laws and regulations.

C. Conflict Minerals

Suppliers shall comply with all applicable laws and regulations regarding conflict minerals, including the Dodd-Frank Wall Street Reform and Consumer Protection Act. Suppliers shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to the Company upon request.

VIII. Monitoring and Enforcement

A. Audits and Inspections

The Company reserves the right to audit or inspect a Supplier's facilities, records, and practices to verify compliance with this Code. Such audits or inspections may be conducted by the Company or by a third-party auditor designated by the Company. Suppliers shall cooperate fully with any such audit or inspection, including:

1. Providing access to relevant facilities, records, and personnel
2. Allowing interviews with employees and management
3. Responding promptly and completely to audit findings and corrective action requests

B. Corrective Action and Termination

If the Company determines that a Supplier has violated this Code, the Company may require the Supplier to take appropriate corrective action. The corrective action process shall include:

1. A written corrective action plan submitted by the Supplier within 30 days of notification
2. Implementation of corrective measures within an agreed-upon timeframe
3. Follow-up audits or inspections to verify the effectiveness of corrective actions

Failure to take such corrective action may result in the termination of the supply agreement or other contractual relationship with the Company. The Company reserves the right to immediately terminate its relationship with any Supplier found to be in serious violation of this Code or applicable laws and regulations.

C. Reporting Violations

Suppliers are encouraged to report any suspected violations of this Code or any other unethical or illegal conduct to the Company's designated compliance officer. Reports can be made confidentially and anonymously through the following channels:

• Email: info@corp-couture.com
• Phone: 925-831-3141

The Company prohibits any form of retaliation against individuals who report suspected violations in good faith.

IX. Implementation and Communication

A. Training and Awareness

Suppliers shall ensure that their employees, subcontractors, and agents are aware of and understand the requirements of this Code. Suppliers shall provide appropriate training on the Code and relevant laws and regulations to their employees, particularly those in positions with responsibility for compliance and ethics.

B. Documentation and Record Keeping

Suppliers shall maintain accurate and complete records demonstrating compliance with this Code and applicable laws and regulations. Such records shall be made available to the Company upon request.

C. Continuous Improvement

Suppliers are encouraged to continuously improve their practices and performance in the areas covered by this Code. Suppliers should regularly assess their compliance with the Code and implement improvements as necessary.

X. Indemnification and Limitation of Liability

A. Indemnification

Supplier agrees to indemnify, defend, and hold harmless the Company, its affiliates, officers, directors, employees, and agents from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to Supplier's breach of this Code or any applicable laws or regulations.

B. Limitation of Liability

In no event shall the Company be liable to Supplier for any indirect, incidental, special, consequential, or punitive damages arising out of or related to this Code or the Company's enforcement thereof, even if the Company has been advised of the possibility of such damages.

XI. Acknowledgment and Agreement

By opening the document and proceeding hencewith, the undersigned Supplier acknowledges receipt of this Supplier Code of Conduct, and agrees to comply with all of its provisions. The Supplier further agrees to ensure that its employees, subcontractors, and agents also comply with this Code.