Dear Partner,

To OTB Group, guaranteeing the quality of its products means also
operating in a transparent and sustainable way. OTB Group is committed
to ensuring safe conditions in the workplace, respecting employee rights,
avoiding any form of child or forced labor, as well as harassment ordiscrimination. OTB Group also commits to protecting the environment
and animal welfare, and to complying with applicable laws concerning
working conditions, environmental management, and ethical businesspractices.
To make sure this commitment is respected, it is essential that not only
the Group and its affiliates, but also the Supplier with whom we partner,
adhere to these principles and strive to improve social and environmental
performance through a process of continuous improvement.
The attached document illustrates in detail the conditions that each OTBGroup's Supplier is required to monitor and comply with. We are asking
you to carefully read such conditions, implement them in your sites andwithin your own supply chain, and to return us the document duly signed
for acceptance by your legal representative.
Please do not hesitate to contact OTB Group if you have questions about
this Code of Conduct, or are seeking support to enhance your social andenvironmental performance.

OTB Group

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

1

CODE OF BEHAVIOUR FOR SUPPLIERS

The Supplier must comply and hereby undertakes the obligation to fullycomply with:•All local and national laws, including social and environmentalregulations;•This Code of Conduct;•Any action and/or initiative by OTB Group aimed to preserve

legality in working conditions.
This Code of Conduct is based on (and aligned with) globally recognizedsocial and environmental standards, particularly, the eight fundamental
ILO conventions and the Universal Declaration of Human Rights.
Unless there is conflict between national law and any Supplier obligationin this Code of Conduct, the Supplier must adhere to the standard that
promotes the highest level of protection for workers, communities, andother rights holders.
By signing this Code of Conduct, the Supplier commits itself (to the single
companies belonging to the OTB Group, with which the Supplier will, fromtime to time, enter into a business relationship) to respect all theobligations set out herein.

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

2

Regular Employment
To every extent possible, work performed by Supplier’s employees must
be on the basis of a recognized employment relationship establishedthrough national law and practice.
Obligations to employees under labour or social security laws andregulations arising from the regular employment relationship shall not be
avoided through the use of labour–only contracting, sub–contracting, orhome–working arrangements, or through apprenticeship schemes where
there is no real intent to impart skills or provide regular employment, norshall any such obligation be avoided through the excessive use of fixed–
term contracts of employment.
Child Labour
Workers must meet the local legal minimum age for employment,
required by the law in force in the country where the manufacturing
facilities are located, the age for completing compulsory education, or beat least 15 years old, whichever is higher. When employing workers under
the age of 18, the Supplier must provide adequate protection against any
conditions that may be hazardous to the health and safety of young
workers. In particular, workers under the age of 18 must be protectedfrom economic exploitation and from performing any work that is likely tobe hazardous or to interfere with their education, or to be harmful to theirhealth or physical, mental, spiritual, moral or social development.
Forced Labour
The Supplier must not use forced or involuntary labour, whetherindentured, bonded, prison or labour obtained through slavery, humantrafficking or otherwise. Workers will not be obligated or forced to makemonetary deposits in relation to their employment, pay recruitment fees
associated with obtaining work, or leave their original identity orimmigration documents to the employer. Workers will have freedom ofOTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

3

movement at their workplace as appropriate to their function, and will befree to terminate the work relationship in compliance with terms set forth
by the laws in force and/or the collective agreements.
Coercion and harassment
The Supplier must treat each employee with dignity and respect and notuse

corporalpunishments,

threats,

verbalharassments,

abuses,intimidation, or other forms of physical, sexual or psychological violence.
Discrimination
The Supplier must not make discriminations in hiring and managing thepersonnel (including as regards, by way of example and not exhaustively,salary treatment, granting of benefits, career advancements, workassignments, dismissals or retirement) on the basis of: race, religion, age,nationality, language, social or ethnic origins, sexual orientation, gender,political or other opinions, property, birth, disability or other personal
conditions which are not connected to experience or capability in the job(as provided for in ILO Equality Conventions 100 and 111). The Suppliershould have an equal opportunity employment policy that promotes
gender equity in employment practices, and ensure that men and women
receive equal pay and conditions for the same jobs.
Freedom of Association
The Supplier must respect the rights of employees to join unions in a
lawful and peaceful manner, and to bargain collective agreements,
without discriminations or interferences of any kind. Where permitted bylaw, the Supplier undertakes to facilitate and not to hinder thedevelopment of methods of aggregation, to enable employees to gather
independently and discuss work-related issues.

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

4Corruption and Bribery
The Supplier must respect local laws and must not engage in any form ofcorrupt practices, including but not limited to extortion, fraud, or bribery.
Practices involving public or private corruption, illegitimate favours, andcollusive behaviour are prohibited with zero tolerance.
Health and Safety
The Supplier must ensure a safe and healthy workplace, in compliancewith all applicable regulations, through maintaining appropriate systems
and practices for emergency preparedness, fire protection, and personalsafety. The Supplier will ensure workers have access to potable water,
sanitary facilities, and adequate lighting and ventilation systems (in any
housing provided for workers). In order to ensure the well-being ofworkers who manufacture products for companies belonging to OTBGroup, the use of sandblasting and/or of equivalent/similar techniques inmanufacturing processes is prohibited.
The Supplier must provide regular health and safety trainings to all
workers and management, and must assign the responsibility for healthand safety to a senior management representative that will carry out
regular risk assessments to prevent accidents and injuries.
Working hours
The Supplier must comply with the laws and the applicable standards ofthe sector concerning working hours, holidays and vacations. The
personnel must receive at least one day off after six consecutive days ofwork, unless the laws or the collective agreements provide flexible
working hours with proper compensatory days of rest.
Wages
The Supplier must respect the right of personnel to a befitting wage whichis always sufficient to meet the employees’ basic needs, and which must

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

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be at least the minimum wage or the appropriate prevailing wage,
whichever is higher, in compliance with all applicable laws. The Suppliermust pay workers on time and provide to all workers legally required
employee benefits, including (by way of example and not exhaustively)
paid leave, health benefits, as well as maternity leave and child care leave
benefits, in compliance with all applicable laws. Deductions from wages
as a disciplinary measure shall not be permitted, nor shall any deduction
from wages, unless where provided for and permitted by applicablenational law or, where not provided for by such national law, only after
the expressed permission of the worker concerned. All the overtime mustbe paid at a premium rate as provided by the national law, the collectiveagreements, or the prevailing standards of the sector, whichever ishigher.
Environment
The Supplier must comply with all applicable environmental laws, andmust provide training to all relevant personnel on environmental policies
and procedures. The Supplier should implement processes and systems
to reduce the use of natural resources such as water and energy, and tominimize waste. OTB Group also recommends the implementation of anenvironmental management system to manage, track, and set goals
related to environmental performance, including waste, water, andenergy.
Animal welfare
The Supplier must respect the animals, and should ensure the highest
standards of animal welfare provided by laws and conventions applicablein the Supplier’s country (or in the countries where the manufacturing
facilities are located), in all the business processes (including themanufacturing processes), through the entire life of the animal. In any
case, any technique to obtain plumes and feathers from live animals areprohibited.

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

6

SubSub-contracting
The Supplier must not engage any subcontractor to perform, in whole orin part, any work and/or activities entrusted to him by OTB Group and/or
by the individual companies belonging to OTB Group, unless expressly
authorized in writing by OTB Group company concerned. In this last case,the Supplier shall be and remain responsible towards the companies
belonging to OTB Group, and with the signing of the present Code of
Conduct expressly assumes this obligation, of the full respect of the Codeof Conduct also by the subcontractor. For the purposes of this Code ofConduct the word “subcontractor” shall mean a supplier who has no direct
relationship with OTB Group and/or with the individual companies
belonging to OTB Group, but which is involved by the Supplier, under theterms and conditions set out above, in the performance of part of thework and/or activities entrusted to the Supplier.
Implementation and grievance processes
The Supplier must establish a process to ensure that the requirements inthis Code of Conduct are implemented and consistently applied in its
facilities. Such management systems should include human resources
policies and procedures that are communicated to workers and whose
implementation is adequately monitored.
The Supplier must also develop and implement an appropriate workplacegrievance mechanism to raise workplace concerns. This mechanism must
be an understandable and transparent process that provides timely
feedback to those concerned, prohibit retaliation, and guarantee
confidentiality of the worker lodging the grievance. The Supplier must
faithfully warn the single company part of OTB Group with which it may
enter in a business relationship of any serious difficulty in applying thisCode of Conduct.

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

7Monitoring and compliance
The Supplier must monitor and modify its management processes andbusiness operations to ensure he aligns with this Code of Conduct. The
Supplier is expected to monitor, measure, and improve the social andenvironmental performance of its facility, using appropriate management
systems and tools.
The Supplier must authorize the single company part of OTB Group withwhich it may enter in a business relationship and its representatives tocarry out monitoring activities to check the compliance with this Code ofConduct, including unannounced inspections (it being understood that theSupplier and the single companies part of OTB Group may decide toprovide a reasonable period of notice, related to such inspections, in therelevant supply agreement) of the manufacturing facilities and thehousing provided to employees, the possibility to check books and records
relating to personnel, and the possibility to make private interviews toemployees. The Supplier agrees to make available at its registered office
all the documentation that may be needed to give evidence of compliancewith this Code of Conduct, not falsify records, coach workers in how toanswer questions, or intentionally mislead the single companies part ofOTB Group or their representatives in any way. Furthermore, the Suppliermust carry out effective corrective actions, which may become necessary
to remedy any failure to comply with this Code of Conduct, within areasonable period in agreement with the single companies part of OTBGroup with which it may enter in a business relationship.
The Supplier declares and guarantees that its structure, its management
processes and business operations are aligned and conform to theprovisions of this Code of Conduct.

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

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Publication
Publication
The Supplier will take the appropriate measures to ensure that therequirements of this Code of Conduct are made known to workers,
through publication of the Code of Conduct in the local language (in theversion provided by OTB Group or by the single companies part of OTBGroup) and in a place easily accessible to employees at all times. It is also
the Supplier’s responsibility to share and enforce these standards withinits own supply chain.
In the event of failure to comply with the provisions and/or commitments
undertaken with this Code of Conduct, the single companies part of OTBGroup with which the Supplier may enter in a business relationship will
be entitled to cancel any order in progress and/or to terminate any
existing contractual relationship with the Supplier, without prejudice tothe right to compensation for damages.

OTB Group
The present Code of Conduct for the Suppliers, from the time of thesubscription, supersedes and replaces any previous Code of Conduct
between the Parties.

____________________________
Place and date

For acceptance:____________________________(Stamp and signature of the legal representative)

OTB
Via dell’Industria, 236042 Breganze (VI) Italy
T +39 0445 306555 / F +39 0445 306955

OTB S.p.A. / cap.soc. Euro 25.000.000 int. vers.
C.F. e REG.IMPRESE VICENZA 01242510269
P.IVA IT01571110244 / R.E.A.N. 170761 CCIAAVI

www.otb.net

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