2019 Md. Lutful Kabir Pioneer Knitwears (BD) Ltd. 1/2/2019

CODE OF CONDUCT

Authorized Date: 01-07-17 Revised Date: 02-01-19 1

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 POLICY AND PROCEDURE APPROVAL COVER SHEET POLICY NAME : CODE OF CONDUCT Existing Policy Number : PC/2/033 Revision : 01 Effected Date : 01/01/2017 Policy Owner : Md. Lutful Kabir New Revised Reaffirmed (No change or only Minor Edits) Rescinded POLICY RATIONAL (Provide a brief explanation of why this policy or proposed changes are necessary) BRIEF SUMMARY of new policy or revisions to an existing policy, results of reaffirmation, or reason for rescinding an existing policy (if additional space is needed, please use a second sheet) : POLICY AND PROCEDURE APPROVAL PROCESS DATES POLICY OWNER: I certify that the policy has been drafted and vetted within unit and other constituent groups. Md. Lutful Kabir In-Charge (Admin, HR & Compliance) Name, Title Signature Date MANAGEMENT REVIEW : Ploicy Owner contacts the Manager (Admin, HR & Compliance) to schedule the policy for review by the Management Review Meeting. The policy owner must email the draft policy to the Manager (Admin, HR & Compliance) at least two weeks prior to the policy appearing before them at a review meeting. Management Review Meeting Date :______________________ Authorization : Samar Shen Saha, Manager (Admin, HR & Compliance) Name & Desig. :_______________________________________________ Signature :_______________________ REVIEW & APPROVAL : After the policy owner integrates the Meeting’s feedback, the policy is presented to the Managing Director/Director for review and approval. Managing Director (Md. Badsha Mia) Approved: ____________________________________ Signature______________________ Date___________ COMMUNICATION / IMPLEMENTATION PLAN Specify the activities that will be undertaken to communicate and implement the new policy or policy changes, including who is responsible for each activity.

Authorized Date: 01-07-17 Revised Date: 02-01-19 2

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 Contents 1. Introduction .............................................................................................................................................................. 3 2. Vision ......................................................................................................................................................................... 3 3. Mission ...................................................................................................................................................................... 3 4. Scope ......................................................................................................................................................................... 3 5. Abbreviation .............................................................................................................................................................. 3 6. Code of Conduct ........................................................................................................................................................ 4 6.1 Compliance with legal regulations .................................................................................................................... 4 6.2 Human Resources.............................................................................................................................................. 4 6.3 Wage ................................................................................................................................................................. 5 6.4 Working Hours .................................................................................................................................................. 6 6.5 Child Labour ...................................................................................................................................................... 6 6.6 Discrimination ................................................................................................................................................... 6 6.7 Remuneration, Compensation & Benefit .......................................................................................................... 6 6.8 Forced Labour ................................................................................................................................................... 7 6.9 Freedom of Association..................................................................................................................................... 7 6.10 Harrasement and Abuse.................................................................................................................................... 7 6.11 Health & Safety ................................................................................................................................................. 8 6.12 Regular Employment Is Provided ...................................................................................................................... 9 6.13 Grievance .......................................................................................................................................................... 9 6.14 Environment .................................................................................................................................................... 10 6.15 Ethical Standard .............................................................................................................................................. 10 6.16 Disciplinary Action ........................................................................................................................................... 11 6.17 Termination and Retrenchment ...................................................................................................................... 11 6.18 Sustainable Compliance .................................................................................................................................. 12

Authorized Date: 01-07-17 Revised Date: 02-01-19 3

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 1. Introduction The name of Pioneer knitwears (BD) Ltd has stood for excellence in our industry for many years. We have all worked hard to guarantee this excellence in both our products exists because of our shared values and our commitment to serve our customers with the greatest amount of respect and integrity. We want to sustain in a sustainable way. The principles in this Code bring our values and beliefs to life by setting clear expectations for our behavior. While the code helps us address some of the most common legal and / or ethical issues and dilemmas we may face, it cannot cover every situation. All of us are, therefore expected to use good judgment and take responsibility for our actions. This Code is drafted in accordance with, and as a complement to, Pioneer knitwears (BD) ltd. Cycle of Goodness, Core values, and management principle. 2. Vision To manufacture products comparable to local law and buyers standards, to be customer-focused and globally competitive through better quality, better working environment, latest technology, ensure sustainability and continuous improvement. 3. Mission A. To manufacture world-class products of outstanding quality that gives our customers a competitive advantage through superior products and value, So we can make every customer satisfaction. B. To encourage employee’s ownership, environment and better working environment under team structure. C. To attain highest level of efficiency, integrity and honesty. D. To ensure a sustainable safety work place for the workers by 2020. 4. Scope This Code of Conduct shall apply to Pioneer Knitwears (BD) Ltd (PKBDL), Pioneer Knitwears (BD) Ltd Section-1(PKBDL-1) & Pioneer Knitwears (BD) Ltd Section-2 (PKBDL-2). 5. Abbreviation PKBDL = Pioneer Knitwears (BD) Ltd. SU = Supplier Unit PU = Production Unit

Authorized Date: 01-07-17 Revised Date: 02-01-19 4

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6. Code of Conduct The present PKBDL Code of Conduct Version 1 aims at setting up the values and principles that the Suplier unit (SU), Production unit (PU), Suppliers and Sub-contract factories strive to implement in their supply chains. PKBDL expect all their business units to observe the Code of Conduct. Pioneer Knitwears (BD) Ltd endorses the following Code of Conducts: 6.1 Compliance with legal regulations A. SU, PU, Suppliers and Sub-contractors shall comply with all applicable laws and regulations, including, without limitation, those relating to labor/child labor, worker health and safety and the environment. B. Admin Manager (Mr. Samar Shen Saha) will responsible for monitoring legal documents. 6.2 Human Resources 6.2.1 Hiring and Employment Practicies SU, PU, Suppliers and Sub-contractors must implement hiring practices that accurately verify workers age and legal right to work in the country prior to employment. All terms and conditions of employment including, but not limited to, hiring, pay, training, promotion, termination, and retirement must be based on an individual’s ability and willingness to do the job. 6.2.2 Prison Labor SU, PU, Suppliers and Sub-contractors must not use prison labor or subcontract work to prisons in any form, including but not limited to, materials, goods and services. 6.2.3 Bonded and Indentured Labor A. SU, PU, Suppliers and Sub-contractors must not use any kind of bonded or indentured employees nor permit or encourage employees to incur debt through recruitment fees, fines, or other means. B. SU, PU, Suppliers and Sub-contractors shall not withhold employees’ original identity papers, deposits, or money or other employees’ property.

Authorized Date: 01-07-17 Revised Date: 02-01-19 5

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6.2.4 Free to Resign A. All employment must be voluntary and employees shall be free to resign from their position with reasonable notice. B. SU, PU, Suppliers and Sub-contractors should not impose unreasonable notice requirements or financial penalties that restrict an employee’s resignation. In the event of separation, Suppliers should pay wages earned for worked hours according to laws and regulations. C. SU, PU, Suppliers and Sub-contractors should adopt a separation policy and procedures written in the languages understood by employees and further ensure employees are informed of its provisions. 6.3 Wage A. SU, PU, Suppliers and Sub-contractors shall pay workers at least the Applicable Minimum Legal wage established by the country within which the workers perform services. B. SU, PU, Suppliers and Sub-contractors shall pay workers overtime or any other legally required pay (e.g. incentive, piece rate, and holiday). Overtime pay rates shall be calculated pursuant to law and will be higher than rates established for a regular shift. C. All Overtime must be voluntary, mutually agreed, and compensated at a premium rate. Overtime may not exceed a maximum of 12 hours a week, except in truly exceptional, unforeseeable circumstances. D. SU, PU, Suppliers and Sub-contractors shall maintain accurate payroll records in accordance with applicable laws for every worker and for each pay period which reflects, at minimum, amount paid, days and hours worked, wage or rate earned per day, hours of overtime, other types of income, and any legal or contractual deductions from pay. Such records shall be retained and kept available for audit for a period of at least three years after the work has been performed. E. SU, PU & Suppliers shall provide every worker with a wage statement in accordance with applicable laws which includes, at minimum, the requirements of BLR-15. C. Monetary Deduction: i) SU, PU, Suppliers and Sub-contractors shall not make any monetary deduction as a result of disciplinary actions. ii) SU, PU, Suppliers and Sub-contractors shall not require monetary deposits for accommodation or PPE, uniforms, tools etc. iii) SU, PU, Suppliers and Sub-contractors shall not require employees to give written consent for deduction for items that are not mandated by law or collective bargaining agreement.

Authorized Date: 01-07-17 Revised Date: 02-01-19 6

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6.4 Working Hours A. Worker wages should be enough to meet basic needs and provide some discretionary income. B. Workers shall not be required to work in an excess of 48 hours a week on a regular basis without workers consent. C. Workers may not be forced to work within working hour period. D. Employees should be given at least 1 rest day in any 7-day period. 6.5 Child Labour A. Workers must be at least 14 years of age, or older if required by local law, including regulations for compulsory education. B. Workers performing hazardous work or working during the night must be at least 18 years of age. C. If child labour is used or identifed, SU, PU, Suppliers and Sub-contractors must provide minimum wage payment to the child until she/he reaches the legal minimum age. Payment should be made on a monthly basis, not in one lump sum. A health screen prior to departure is also required, as well as compensation for transportation and accommodation for a child’s relatives to take her/him back home. If the child is willing to attend lessons, suppliers must bear the school fees until the child meets the legal minimum age, at which point the employee should be given the opportunity to be re-employed. 6.6 Discrimination A. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, mental or physical handicap, ethnic, sexual orientation, union membership, political affiliation or personal characteristics. 6.7 Remuneration, Compensation & Benefit A. Employee compensation – including wages, overtime pay, benefts and paid leave - shall not be lower than the relevant minimum wage applicable in the given Legal Local Law. B. All withholdings or deductions from wages must adhere to the terms and scope provided for pursuant to local laws.

Authorized Date: 01-07-17 Revised Date: 02-01-19 7

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6.8 Forced Labour A. All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions. B. The use of forced or compulsory or unpaid labour in all its forms, including prison labour and unpaid overtime work, is prohibited. C. SU, PU, Suppliers shall not require workers to make unreasonable deposits/financial guarantees and shall not confiscate identity documents off any worker (such as passports, NID, identity cards, etc.). No abusive delayed payment of wages shall occur. D. Bonded labour is prohibited. SU, PU & Suppliers shall not use any form of bonded labour nor permit or encourage workers to incur debt through recruitment fees or other means. E. Indentured labour is prohibited. SU, PU & Suppliers shall respect the right of workers to terminate their employment after legal notice. Suppliers shall respect the right of workers to leave the workplace and factory after their shift. F. SU, PU, Suppliers and Sub-contractors shall not restrict the movement of employees in their designated work areas and provide free access to drinking water and toilets. This applies for both the employment site and dormitories. 6.9 Freedom of Association A. Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. B. The employer adopts an open attitude towards the activities of trade unions and their organisational activities. C. Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace. D. Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining. 6.10 Harrasement and Abuse Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Authorized Date: 01-07-17 Revised Date: 02-01-19 8

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6.11 Health & Safety A. Employees’ health and safety is a priority at all times. B. Building Safety i. Safe and hygienic working environment shall be provided in accordance with the local laws and regulations, this include and not limited to employee health and safety, sanitation, fire safety, risk protection, electrical, mechanical and structural safety. ii. Buildings shall be safe, regularly maintained, well-lit and ventilated, clean, adequate heated and cooled. C. Fire Safety & Emergency Preparation i. Emergency exits on all floors must be clearly marked, unblocked and unlocked during working hours. ii. Suppliers must have procedures to prepare for possible emergencies and natural disasters such as fire, earthquakes, flooding, chemical spills, etc. These procedures must be written in local language that all employees can understand. iii. All employees shall be regularly trained for how to react in case of emergency. iv. Regular fire and emergency evacuation drills for all employees are required. D. Electrical Safety i. SU, PU & Suppliers must keep wiring and electrical system in safe condition. ii. All electrical wires must be properly insulated. All electrical junction boxes must be covered All electrical connectors must be in good condition. All electrical panels are labelled and breakers identify the equipment they protect. E. Accidents & First Aid i. SU, PU & Suppliers shall work proactively and take adequate steps to avoid accidents or injury to health in the workplace. Appropriate and effective personal protective equipment shall be provided as needed. ii. Sufficient amount of first aid kits and trained first aider must be available. iii. Where legally required a doctor or nurse should be available during working hours. F. Clean toilet facilities and potable water shall be provided and accessible at all times. G. Dormitory (if applicable) i. When dormitory is provided, it shall be safe, clean and meet the basic needs of the employees. It must be in compliance with all housing regulations and occupancy requirements. ii. The safety and cleanliness under point B-F above should also cover the dormitory. iii. Dormitory should be separated from the workplace and have a separate entrance. iv. Employees should have free access to the dormitory.

Authorized Date: 01-07-17 Revised Date: 02-01-19 9

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 H. Canteen, Cafeteria and Kitchen (if applicable) i. Canteen, cafeteria and kitchen provided should be clean and meet the hygienic standard for food preparation and storage. Sufficient number of dining tables and seats, proper lighting and ventilation. ii. Sufficient number of fire extinguishers and fire blanket should be available. I. SU, PU & Suppliers shall assign a senior management representative for the health and safety responsibility. J. SU, PU & Suppliers shall undertake sufficient training of workers and management in waste management, handling and disposal of chemicals and other dangerous materials. K. SU, PU & Suppliers shall provide regular and recorded health and safety training to employees and management; such training shall be repeated for all new employees. 6.12 Regular Employment Is Provided A. To every extent possible work performed must be on the basis of recognized employment relationship established through national law and practice. B. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment. 6.13 Grievance A. SU, PU & Suppliers should develop a written grievance policy and provide multiple channels for employees to raise concerns and suggestions confidentially or anonymously without fear of retaliation. B. SU, PU & Suppliers should develop effective grievance procedures and inform all employees at the start of employment. C. All grievances should be investigated, documented and the decision for solutions shall be communicated back to the employee.

Authorized Date: 01-07-17 Revised Date: 02-01-19 10

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6.14 Environment A. SU, PU & Suppliers must act responsibly in environmental protection and comply with all applicable environmental laws and regulations. B. Environmental Permits i. SU, PU & Suppliers must have the relevant environmental permits and licences for its operations. C. Chemicals Handling i. Chemical containers must be properly labelled and stored safely. ii. Material Safety Data Sheet (MSDS) must be available in local language in the factory. iii. Instructions on the MSDS must be followed. D. Wastewater Treatment i. Wastewater from wet processing must be treated before discharge. ii. Treated wastewater quality must meet the local requirements. E. Waste Management i. Hazardous waste and by-products must be properly managed in compliance with the applicable law and regulations. 6.15 Ethical Standard A. No Unauthorized Subcontracting i. PKBDL must keep Business partners informed at all times of where each product is being produced, including subcontracting and homework. ii. PKBDL shall not subcontract any work without the prior written authorization of Business partner. All Suppliers, which subcontract work for PKBDL, shall be responsible for the subcontractors’ compliance with this Code. iii. All Suppliers and their subcontractors shall apply the principles of the Code to any homeworker involved in their supply chain, and they shall give transparency to the locations and working conditions of said homeworkers. B. No Bribery or Corruption i. PKBDL must not engage in any unethical practices, such as paying bribes or influencing the outcome by unethical means. ii. Corruption, extortion, and embezzlement, in any form, are strictly prohibited. iii. PKBDL shall not offer or accept bribes or other means of obtaining undue or improper advantage.

Authorized Date: 01-07-17 Revised Date: 02-01-19 11

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6.16 Disciplinary Action A. SU, PU & Suppliers should establish a policy on employee discipline. All disciplinary measures shall be in accordance with law. Suppliers should train all employees on the policy at the start of the employment. B. Under no circumstance, SU, PU & Suppliers shall allow physical punishment or public embarrassment as disciplinary measures. C. SU, PU & Suppliers’ procedures for employee discipline should follow a progressive disciplinary model that includes an escalating series of verbal and written warnings prior to suspension or dismissal. D. SU, PU & Suppliers shall not use unlawful fines as a disciplinary measure. E. SU, PU & Suppliers should train managers, supervisors and team leaders on the grievance policy and procedures and their job performance should include their demonstrated ability to follow the procedures. F. Management and supervisors should implement the procedures and document any disciplinary actions. 6.17 Termination and Retrenchment A. In the event of retrenchment or termination of employment, SU, PU, Suppliers and Sub-contractors shall provide affected employees reasons or criteria of temporary or permanent separation from employment according to law. B. SU, PU, Suppliers and Sub-contractors shall provide advance notice or pay in lieu of notice as required by law. C. SU, PU, Suppliers and Sub-contractors must not require employees to sign a declaration of good health, waivers or release of legally mandated rights in exchange for receiving legal severance/benefits of separation.

Authorized Date: 01-07-17 Revised Date: 02-01-19 12

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01 6.18 Sustainable Compliance A. Systematic Approach i. To maintain compliance with this Code, local legal requirements and international applicable law and regulations, it is important that our Business Partners adopt similar principles and have the necessary policies and management system in place. B. Monitoring & Enforcement i. SU expects PUs respect this code and actively apply the above principles to achieve sustainable compliance. ii. PKBDL (SU) is responsible for the compliance of their contractors, subcontractors and other business partners, SU must ensure they are in compliance with this Code and all the applicable law. iii. SU will work with PUs to support any necessary improvement to achieve sustainable solutions. iv. SU/PU will share any best practice among the PUs. C. Verification of Compliance with the Code i. In exercising control over its supply chain, PKBDL will conduct audits which will be carried out by appropriately trained employees. ii. PKBDL may conduct announced and unannounced audits at facilities producing goods for the company. During an audit, the supplier shall provide the ordering party with all documentation necessary to verify compliance with the Code allow employees to be interviewed by the auditing party (including off-site interviews) and allow production facility inspections. D. Corrective Action i. PKBDL will follow up the Pus’ & Suppliers’ corrective action plan regularly and verify that non- compliance issues have been remediated. ii. Unable or unwilling to cooperate, or having repeated serious violations of this Code, this breach may lead to reduced, suspend or stopping business relationship with PKBDL.

Authorized Date: 01-07-17 Revised Date: 02-01-19 13

PIONEER KNITWEARS (BD) LTD. C O D E O F C O N D U C T PC/2/033 Revision-01