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Town Shoes Limited
Code of Conduct
Town Shoes Limited conducts its business in a fair and ethical manner. We are concerned about human rights and
expect our business partners to share our ethical concerns.
We use the following standards and expect compliance with these standards by our business partners including all
manufacturers, agents, contractors, subcontractors and suppliers utilized in the manufacture and finishing of products
that are ordered by TSL.
1) Safe and healthy workplace. We seek business partners who provide a safe and healthy workplace that
complies with the local laws. We seek business partners who provide safe and healthy residential facilities for
their workers in compliance with local standards.
2) No forced or compulsory labor. We will not knowingly engage business partners who use forced labor in the
manufacture of products for TSL.
3) No Child labor. We will not knowingly work with business partners who utilize child labor. We define child labor
as either being at or below the local minimum working age.
4) Fair Disciplinary practices. We will not knowingly work with business partners who utilize physical or mental
punishment against their employees.
5) No discrimination. While we respect cultural differences, we believe workers should be employed based on
their abilities rather than their race, gender, belief or personal characteristic and encourage our business
partners to eliminate discrimination in their workplaces.
6) Reasonable working hours and overtime. We seek business partners that do not require more than a 60 hour
work week (or lower if prescribed by local laws) on a regular scheduled basis, except for compensated overtime
in compliance with local laws.
7) Fair wages. We seek business partners that provide wages and benefits in compliance with local laws or
prevailing local industry wage, whichever is higher. We encourage our business partners to commit to the
betterment of wage and benefit levels that address the basic needs of workers and their families.
8) Freedom of association. The lawful exercise of workers’ rights of free association shall be respected and not
restricted or interfered in, and workers lawfully exercising those rights shall not be threatened or penalized.
9) Environment. Environmental laws and regulations must be complied with.
10) Country of origin. We will not knowingly work with business partners who use deceptive practices to
deliberately misrepresent country of origin in order to evade quota or other import restrictions or duties on any
products that will be sold to TSL.
11) Monitoring of Compliance. Business Partners authorize TSL or a 3rd party representing TSL to conduct scheduled
and unscheduled inspections of vendors’ facilities for the purpose of ensuring compliance with this Code of
Conduct.
I have read this TSL code of conduct and agree to comply with its terms and conditions.
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Town Shoes Limited
Global Compliance Program
Standards of Vendor Engagement
Safe and Healthy Workplace
A safe and healthy workplace is essential for the employees working in your factories. The factory needs to provide the
following to ensure the employees can quickly react in case of emergency:
1) Enough fire extinguishers and/or hydrants (with hoses) for the size of the factory and in accordance with the
local laws.
2) Proper and working emergency lighting (with a battery back-up) must be installed throughout the factory.
3) Adequate number of emergency exits. Best practice is to ensure every employee has access to at least two
exits.
4) All Exits must be unblocked (from the inside and outside), unobstructed and clearly marked. The exit doors
should push open not pull open.
5) All employees must have basic training on how to use the fire extinguishers and or hydrants, location of the
emergency exits and first aid training.
6) Personal protective equipment such as eyewear, ear plugs and face masks should be made available to
employees when applicable. Employees should also be trained in the proper use and educated on why they
should use protective equipment.
7) If dormitories are provided, they must be in compliance with all applicable laws in regards to fire & safety, room
size and number of occupants per room.
No forced of Compulsory Labor
Town Shoes Limited has a “zero” tolerance policy towards the use of forced or compulsory labor.
1) Employees must be able to decline overtime without penalty (financial or other).
2) Employees should not be subject to large financial employment deposits to begin or retain employment.
3) No prison labor may be used.
Fair Disciplinary Practices
Workers should not be unfairly punished for things such as declining overtime, being tardy, producing defective goods or
poor production. All factories should have written rules regarding disciplinary procedures and those policies must be
communicated to the workers.
1) Disciplinary practices must be in accordance to applicable local laws.
2) Town Shoes Limited has a “zero” tolerance policy towards corporal punishment.
3) Corporal punishment is defined as “punishment inflicted on a person’s body”.
No Discrimination
Workers should be hired based on qualifications not gender, race, personal beliefs or characteristics.
1) All employees are to be treated with respect. This includes workers imported from another country.
2) Pregnancy and or HIV testing should not be conducted at time of hire unless required by local law.
Reasonable Working hours and Overtime
Working hours should not exceed local laws.
1) Town Shoes Limited establishes a maximum work week (including overtime) of 60 hours. If local law specifies a
work week (including overtime) of less than 60 hours, local law must be followed.
2) Employees should receive minimum one day of rest per week (one day off in seven).
3) Employees must be able to decline overtime without penalty (financial or other).
4) Vendors, Agents and Distributors must know and follow the local law for each country of production.
Fair Wages
Employees must be paid for all hours worked. Use of time clock or scale is required to track employee’s hours (both
regular and overtime).
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2)
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Local laws regarding wages and overtime compensation must be followed.
Employees should be paid in a timely manner.
Any payroll deductions must be in accordance with local laws.
Employees should not be held responsible for damaged goods.
No Child Labor
Child is defined by Town Shoes Limited as being at or below the local minimum working age.
1) Town Shoes Limited has a “zero” tolerance policy towards the use of child labor. It is TSL’s policy to not accept
product produced by child labor.
2) Apprenticeship programs must be fully documented and in compliance with applicable local laws.
3) The factory must maintain complete and accurate personnel records for all employees including temporary or
seasonal workers.
4) Vendors must know and follow the local law for each country of production.
Country of Origin
Town Shoes Limited will not accept any merchandise that was illegally transhipped into Canada per Canadian Customs
and Border Services.
1) Per Canadian Customs and Border Services, illegal transhipment is a false declaration if information given to
circumvent existing Canadian trade laws for the purpose of avoiding quotas, embargoes or prohibitions or to
obtain preferential duty treatment.
2) The Vendor/factory should maintain all production and import/export records for a minimum period of five
years. These records should remain at the factory for a minimum of one year and be provided upon request
within 72 hours.
Zero Tolerance/Severe Violation
If any of the below listed 4 standards are violated at any point, the factory will be made non-compliant and will not be
allowed to produce Town Shoes Limited product for an indefinite period of time. If the factory did produce Town Shoes
Limited products, Town Shoes Limited could not accept this merchandise.
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2)
3)
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No Child Labor
No Forced or Compulsory Labor
Fair Disciplinary Practices and No Corporal Punishment
Country of Origin/Illegally transhipped Goods