Code of Conduct

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Index

Introduction 3
1. No forced labour 3
2. No child labour 3
3. No discrimination 4
4. Respect for freedom of association and collective bargaining 4
5. No harsh or inhumane treatment 4
6. Safe and hygienic working conditions 4
7. Wages are paid 5
8. Working hours are not excessive 5
9. Regular employment 5
10. Traceability of production 6
11. Health and Safety of products 6
12. Environmental awareness 6
13. Confidentiality of information 6

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Introduction

The BDSPL Code of Conduct for Manufacturers and Suppliers (hereinafter, the Code)
defines minimum standards of ethical and responsible behavior which must be met by
the manufacturers and suppliers of the products commercialized by BDSPL in the course
of its business, in line with the corporate culture of BDSPL Group (hereinafter BDSPL),
firmly based on the respect for Human and Labour Rights.

BDSPL undertakes to allocate the appropriate resources so that manufacturers and

suppliers are acquainted with and understand this Code and are able to ensure its
compliance.

The Code shall be applied to all manufacturers and suppliers that take part in the
purchasing, manufacturing and finishing processes and fosters and is based upon the
following general principles that define BDSPL’s ethical behavior:

- All BDSPL’s operations are developed under an ethical and responsible

perspective.
- All persons, individuals or entities, who maintain, directly or indirectly, any kind
of employment, economic, social and/or industrial relationship with BDSPL, are
treated fairly and with dignity.
- All BDSPL’s activities are carried out in a manner that most respects the
environment.
- All manufacturers and suppliers (production centers that are not property of
BDSPL) fully adhere to these commitments and undertake to ensure that the
standards which are set forth in the Code are met.

1. No forced labour
BDSPL shall not allow any form of forced or involuntary labour in their manufacturers
and suppliers. They may not require their employees to make any kind of “deposits”, nor
are they entitled to retain employees’ identity documents.

Manufacturers shall acknowledge the right of their employees to leave their employer
after reasonable notice.

2. No child labour
Manufacturers and suppliers shall not employ minors. BDSPL defines minors as those
persons who have not yet reached their 16 th birthday. In cases where local legislation
stipulates a higher minimum age, the higher limit shall apply.2

Persons with the ages between of 16 and 18 years will be considered young workers.
Young workers shall not work during night hours or in hazardous conditions.

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 3. No discrimination
Manufacturers and suppliers shall not apply any type of discriminatory practice with
regards the recruitment, compensation, access to training, promotion, termination of the
employment agreement or retirement, based on race, caste, creed, nationality, religion,
age, physical or mental disability, gender, marital status, sexual orientation and/or union
membership or political affiliation4.

4. Respect for freedom of association and collective

bargaining
Manufacturers and suppliers shall ensure that their employees, without distinction, have
the right of association, union membership and collective bargaining. No retaliation may
arise from the exercise of such right and no remuneration or payment whatsoever may
be offered to the employees in order to hinder the exercise of such a right. Likewise, they
shall adopt an open and collaborative attitude towards the activities of Trade Unions.

Workers’ representatives shall be protected from any type of discrimination and shall be
free to carry out their representative functions in their workplace.

Where the rights to Freedom of Association and Collective Bargaining are restricted
under law, the appropriate channels to ensure a reasonable and independent exercise of
such rights must be designed5.

5. No harsh or inhumane treatment

Manufacturers and suppliers shall treat their employees with dignity and respect. Under
no circumstances shall physical punishment, sexual or racial harassment, verbal or
power abuse or any other form of harassment or intimidation be permitted.

6. Safe and hygienic working conditions

Manufacturers and suppliers shall provide a safe and healthy workplace to their
employees, ensuring minimum conditions of light, ventilation, hygiene, fire prevention,
safety measures and access to a drinking water supply.

Workers shall have access to clean toilets facilities and drinking water. Where necessary,
facilities for food storage shall be provided.

Accommodation, where provided, shall be clean and safe.

Manufacturers and suppliers shall take the required steps to prevent accidents and
injuries to health of their workers, by minimizing as much as possible the risks inherent
to work.

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Manufacturers and suppliers shall provide their workers with regular training in the
matter of health and safety at work. The company shall keep an appropriate record of the
training courses done. Likewise, they shall appoint a person in charge of health and
safety within the Management, duly authorized and with the appropriate decision taking
power 6.

7. Wages are paid

Manufacturers and suppliers shall ensure that wages paid meet at least the minimum
legal or collective bargain agreement, should this latter be higher. In any event, wages
should always be enough to meet at least the basic needs of workers and their families
and any other which might be considered as reasonable additional needs.

Manufacturers and suppliers shall not make any withholdings and/or deductions from
wages for disciplinary purposes, nor for any reasons other than those provided in the
applicable regulations, without the express authorization of workers. Likewise, they shall
provide all workers with: written and understandable information about their wages
conditions upon their recruitment, and detailed information about the particulars of their
wages every time that these are paid.

Manufacturers and suppliers shall also ensure that wages and any other allowances or
benefits are paid on time and are rendered in full compliance with all applicable laws and
specifically, that payments are made in the manner that best suits the workers7.

8. Working hours are not excessive

Manufacturers and suppliers shall adjust the length of the working day to the provisions
of the applicable laws or of the collective bargain agreement applicable for the sector in
question, if the latter affords greater protection for the workers.

Manufacturers and suppliers shall not require their employees to work, as a rule of
thumb, in excess of 48 hours a week and workers shall be granted at least one day off for
every 7 calendar day period on average.

Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded
on a regular basis and shall always be compensated at a premium rate, pursuant to the
provisions of the prevailing regulations in force8.

9. Regular employment
Manufacturers and suppliers undertake that all the employment formulas they use are
part of the applicable local laws. Thus, they shall not impair the rights of workers
acknowledged under labour and social security laws and regulations by using schemes
that have no real intention to promote regular employment in the framework of regular
employment relationships.

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 10. Traceability of production
Manufacturers and suppliers shall not assign any work to third parties without the prior
written authorization of BDSPL. Those who outsource any work shall be responsible for
the enforcement of the Code by these third parties and their employees.

Likewise, manufacturers and suppliers shall apply the principles of this Code to any
homeworker involved in their supply chain, and shall give transparency to the locations
and working conditions of said homeworkers.

11. Health and Safety of products

Manufacturers and suppliers are responsible for all products supplied to BDSPL to
comply with BDSPL health and safety product standards so that the commercialized
products do not entail any risk to customers.

12. Environmental awareness

Manufacturers and suppliers shall be duly committed at all times to protect the
environment and shall comply with the standards and requirements.

Likewise, they commit to comply with environmental standards established by BDSPL

including, if applicable, the necessary measures to reduce and compensate such impact in
order to apply said standards.

13. Confidentiality of information

Manufacturers and suppliers shall preserve the integrity and confidentiality of the
information they may receive as a consequence of their commercial relationship with
BDSPL.

The obligation of confidentiality will remain once the relation with BDSPL is terminated
and it will include the obligation to return any material related to the company held by
the manufacturer or supplier.

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 Post: Bartech data system pvt ltd.
Add - priya industrial bldg., plot no.05, survey no. 50, sativali, near regal
industrial estate, vasai east, 401208, dist. Palghar, maharashtra.

 Email: [email protected]

 +91 9769798705.