SER PROGRAMME(Social and Environmental Responsibility Programme)

Contents

• Preamble• Compliance• Social Standards • Environmental Conduct• Workplace Health & Safety• Product Safety

PreambleLeighmans.com is aware that successful and sustainable business performance can only be attained when responsibility for its clients, employees, the company and the environment can be seen to be taken. Leighmans.com has decided to act on this awareness by committing to the following programme. It comprises the basic demands of the Business Social Compliance Initiative, the guidelines of the Promotional Products Association International (PPAI), and the conventions of the International Labour Organization (ILO, www.ilo.org) as well as the company’s own goals.

This programme relates to both company processes and products.

With respect to products which are not manufactured by Leighmans.com itself, this programme is also to be complied with by the original suppliers (OES, 1st tiers) and their suppliers (2nd tiers), as the basis of their cooperation. The aim is to ensure that the expectations of our customers, the society, and the respective authorities are fully met.

Preamble

These expectations are:• Compliance with legal requirements• Conformity with social standards• Observance of ethical principles• Avoidance of hazards to people and the environment• The protection of resources in conservation of the• environment• The minimisation of the effects of pollution on people

and the• Environment

Preamble

This is only possible if all the parties involved undertake to act in accordance with this programme.

In order to implement the programme together with our suppliers and partners and to check its progress, we will audit our processes, suppliers and partners all over the world.

In this way, we can guarantee that the aspects covered in this programme are met and that our international quality lead for our products is maintained, thereby also securing the success of the company for the future. This is only possible if all the parties involved undertake to act in accordance with this programme.

Compliance with Legal Requirements

Leighmans.com products are sold all over the world. This means that not only must the legal regulations of the country of manufacture be complied with respect to processes and products, but the legal requirements of the respective markets must also be adhered to.

Compliance with Legal Requirements

Legal requirements apply with respect to the following (and other) aspects:

• Raw materials• Operational facilities, health and safety at work• Work times and wages• Human rights and social responsibility on the part of the• employer• Production processes• Refuse disposal processes• Packaging• Ready-made products• Product information and user instructions/product• Declarations

Compliance with Legal Requirements

The laws prevailing in the country of manufacture are of course to be observed and complied with by the respective manufacturer, at their own responsibility. The legal requirements of the sales markets are listed in the respective product specifications or quality agreements by Leighmans.com.

Social Standards

Leighmans.com commits to the eight fundamental principles of the International Labour Organization (ILO, www.ilo.org) which is an organization of the United Nations (UN) and moreover Leighmans.com

commits to the demands of “Social Accountability International” (SAI,www.sa-intl.org) which are integrated as elements in the international ethical workplace management system SA 8000

Social Standards• Freedom of association and right to collective bargaining with employers

• No forced labour like work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily; forbiddance of forced or compulsory labour as a means of political coercion or education or as a punishment for holding or expressing political views or views ideologically opposed to the established political, social or economic system; as a means of labour discipline; as a punishment for having participated in strikes; and as a means of racial, social, national or religious discrimination

• No corporal punishment, mental or physical coercion or verbal abuse

Minimum Age for special work, forbiddance of employment and misuse of children

Minimum Age for special work, forbiddance of employment and misuse of children

Social Standards• Equal remuneration for men and women workers for work of equal value; no

discrimination race, colour, sex, religion, political opinion, national extraction or social origin, handicap, union or political affiliation, no sexual harassment.

• Provide a safe and healthy work environment; take steps to prevent injuries; regular health and safety worker training; system to detect threats to health and safety; access to bathrooms and potable water

• Working hours: Comply with the applicable law but, in any event, no more than 48 hours per week with at least one day off for every seven day period; voluntary overtime paid at a premium rate and not to exceed 12 hours per week on a regular basis; overtime may be mandatory if part of a collective bargaining agreement

• Compensation: Wages paid for a standard work week must meet the legal and industry standards and be sufficient to meet the basic needs of workers and their families; no disciplinary deductions

Environmental Conduct• Conduct that shows due concern for the environment relates to the company,

its manufacturing processes and products.

• Suppliers of Leighmans.com maintain environmental management systems which cover the consumption of resources and energy as well as refuse disposal processes. When investing in new machinery and initiating new processes, great attention is paid to attaining the highest possible level of energy efficiency.

• If possible own production refuse is recycled and for example, substitutes about 20% of raw material in the pen production which is saved. All production waste in our factories is subjected to re-use/ reutilisation. For instance, waste metal from refill tip production is degreased, melted down and made into new material for refill tips. The oil which is washed out is also utilised.

• Waste from offices is sorted, with paper and card being separated from the general refuse, and recycled or used for energy generation.

Environmental Conduct• Solvent-based refuse are disposed off by certified refuse companies

and also used as substitute fuel.

• Mixed plastic refuse, which cannot be reincorporated in the production process, is removed by outside companies and used as a raw material for other processes.

• Inks are supplied in returnable containers.

• 90 % of paperboard containers of raw mug green ware is reused as shipping packaging for finished goods. The waste heat of the mug kilns is used for heating the production hall. Most of the industrial waste heat of the exhaust air is recaptured by heat exchangers for to temper the fresh air.

Environmental Conduct• Solvent-based refuse are disposed off by certified refuse companies

and also used as substitute fuel.

• Mixed plastic refuse, which cannot be reincorporated in the production process, is removed by outside companies and used as a raw material for other processes.

• Inks are supplied in returnable containers.

• 90 % of paperboard containers of raw mug green ware is reused as shipping packaging for finished goods. The waste heat of the mug kilns is used for heating the production hall. Most of the industrial waste heat of the exhaust air is recaptured by heat exchangers for to temper the fresh air.

Environmental ConductMoreover, Leighmans.com attaches top priority to the following product properties:

• Reusability• Long product life-cycle due to high value, robustness and

permanent• sturdiness• Can be dismantled and individual parts recycled into reusable• raw materials• Protection of resources by using high rate of recycled• materials• Biological degradability and compostability by selecting particular• materials for particular products• Waste reduction by using optimised packaging

Environmental Conduct• Leighmans.com products only use processes and materials that are

guaranteed free of pollutants within statutory limits. Leighmans.com requires that its suppliers and OEMs adhere to the respective legal standards with their products.

• The use of unwanted or statutory limited substances like for instance heavy metals, polycyclic aromatic hydrocarbons, special phthalates, polychlorinated/-bromated biphenyls, carcinogenic or mutagenic substances and so on is avoided in the production processes or, where not avoidable, severely supervised for to exclude health risks for employees and exposure of the environment. For to limit the content of these substances in finished products only raw materials are used which comply with these specifications and it is ensured that such unwanted substances can’t enter the flow of material.

• Adherence to these standards is subjected to random checking by accredited test laboratories.

• Protection of the environment by applying robust and durable products is a matter of great importance to Leighmans.com. We achieve this primarily as a result of our high quality standards and our functional and aesthetic, high-quality styling, for which we have received numerous awards.

Workplace Safety & Health• Workplace safety relates to the handling of dangerous substances

and operating materials or materials which can endanger health.

• Besides the before described avoiding or limiting unwanted harmful to health substances or environmental pollution substances special measures for the use of dangerous substances are done. The maximum allowed concentration of volatile organic compounds (VOC) is undercut through sufficient ventilation and air extraction.

• Dangerous areas of production facilities are secured by protection guards or other protective devices, to prevent unintentional personal injury. Safety devices are connected to automatic shutdown mechanisms; production facilities will therefore only function when the safety device is applied.

Workplace Safety & Health• Employees are trained in handling such equipment before they

take up their work. Moreover, workplace safety seminars are held regularly; these are compulsory and attendance is checked.

• Such measures are for example in Germany outlined in legal accident prevention directives (UVV) which are strictly adhered.

• Leighmans.com also expects the same standards of its suppliers; adherence is checked in the form of audits

Product SafetyLeighmans.com products which are marketed for use by children fulfill the requirements of child safety as per DIN EN 71, ISO 11540:1993 and BS 7272-2:2000 and ASTM F963. Should they contain small parts which are in danger of being swallowed by babies or small children, they are marketed by Leighmans.com with a notification of age restriction; they are designed so as not to present a choking hazard and to ensure that they present no health risk.

General product safety is ensured by avoiding sharp corners and edges and adopting a design review in the development of the product which comply with the European directive 2001/95/EC (product safety).

Only non-toxic writing pastes and inks are used.

The legal requirements of the key markets (Europe, USA, Russia, India and China) concerning the ingredients of Leighmans.com-products are adhered.

Product SafetyThese are e.g. the European directive concerning limiting of dangerous/hazardous substances and preparations (76/769/EEC), in which many substances as for example heavy metals regulated, and the respective revisions and amendments, e.g.:

• 2002/61/EC: ban of special AZO-colourants• 2002/45EC: short chain chlorinated paraffines• 2003/11/EC: penta- and octabromated diphenylethers• 1999/43/EC: special carcinogenic colourants• 2005/84/EC: ban of phthalates with risks for health• Eminently important for the American market are:• US Toxic Substances Control Act (TSCA)• Federal Hazardous Substances Act• California Proposition 65

Product SafetyArt materials / products like e.g. fibre pens, crayons, pencils, inks or fountain pen nibs have to comply with ASTM D-4236 and ASTM F963 it they are provided for the use through children.

Substances like heavy metals, polyaromatic hydrocarbons (PAH), polychlorinated and –bromated biphenyls and nonylphenole are especially checked. Parts, which may have enduring skin contact don’t contain natural latex what can cause allergies (thea are “latex free”).

Mugs and products, which are designated for to come in contact with food furthermore are liable to the European directive 2005/31/EG.

Other important standards and rules for Leighmans.com-products are e.g. ISO 12757 (ballpen refills), EN 71 (safety of toys) or EN 1811 and EN 12472 (nickel abrasion). This listing is based on the acquaintance at declaration date of this programme and isn’t complete but should demonstrate exemplary which high requirements are related to Leighmans.com-products.

Product SafetyTo achieve compliance with these standards following measures are done by Leighmans.com:

Leighmans.com only employs raw materials which are safe to use and have been tested to ensure that they are free of pollutants subject to permissible limits.

Leighmans.com only buys from suppliers who have been approved following due inspection and extensive auditing and who guarantee that that their products comply with the laws and directives concerning limited pollutants.

Leighmans.com performs (random) checks to ensure conformity with legal requirements concerning limited pollutants.

Leighmans.com has established a comprehensive approval process for new products, which covers product safety aspects.

Leighmans.com only charges accredited institutes to perform chemical analyses.

SER PROGRAMME(Social and Environmental Responsibility Programme)