Code of Conduct

It is the desire of Exxel Outdoors, LLC, its Subsidiaries and Divisions, to not only be a good citizen of the United States, but also to conduct business in an ethical and moral manner in all of the countries of the world in which we do business. As Exxel’s sourcing and customer base expands to include more diverse cultures, we must ensure that the business people and companies with which we associate have the same values that we expect from our own employees. To achieve this, Exxel subscribes, and we ask that our business partners subscribe, to the following principles in conducting business.

Ethical Standards: We respect the ethical and moral standards and beliefs of all peoples and cultures with whom we do business. We, in turn, expect our business partners to respect our rules and procedures.

Legal Requirements: We expect our employees and business partners to abide by the laws of the countries in which we conduct business. We also expect that International law related to the conduct of business between Nations be followed at all times.

Health and Safety: We are committed to have a safe and healthy working environment in all the facilities that Exxel owns and operates. We also expect that any business partners to whom we provide work will endeavor to provide a safe and healthy work environment for the employees and also in the living facilities provided to the employees, should such facilities be provided.

Environmental Safekeeping: We believe that the environment in which we live is ours to maintain and protect. We subscribe to manufacturing practices that ensure the safekeeping of our natural resources and ecological surroundings, and expect our business partners to also adhere to these principles.

Wages and Benefits: The wage and benefit structure of our business partners must comply with the applicable Country or State laws.

Working Hours: We expect our business partners to operate based on prevailing local work hours. Any time worked over the norm for the area should be compensated at the overtime rate as prescribed by the local labor laws and should be worked voluntarily. Subject to the requirements of local law, a regularly scheduled workweek including overtime should not exceed sixty (60) hours (except in extraordinary business circumstances). All employees are entitled to at least one day off in every seven-day period.

Child Labor: The use of child labor is not permissible. For a definition of “child”, we will first look to the national laws of the country in which business is being conducted. If, however, the laws of that country do not provide such a definition or if the definition includes individuals below the age of 15, we will define “child”, for purposes of determining use of illegal child labor, as anyone who is: (a) Less than 15; or (b) Younger than the compulsory age to be in school in the country in which business is being conducted, if that age is higher than 15.

Prison/Forced Labor: We will not knowingly utilize or purchase materials and/or product manufactured by prison or forced labor – indentured, bonded or otherwise, or from anyone engaged in human trafficking or slavery. We also do not condone the practice of involuntary employee “deposits”, withholding of identity papers or any other practice that would restrict free movement of employees.

Discrimination: We recognize and are aware that cultural differences will exist between various peoples. However, we do believe that people should be employed based on their ability to perform a needed function; not on the basis of personal beliefs or characteristics.

Freedom of Association: We recognize and respect the right of employees to exercise their lawful rights of free association, including joining or not joining any association. We expect our business partners to also adhere to these principles.

Disciplinary Practices: We will not condone any type of harassment, abuse, or corporal, mental or physical punishment by a business partner or an employee.