Tailgate Tikes Code of Conduct

Effective July 2026

Tailgate Tikes LLC is committed to producing premium children's products in workplaces that respect the rights, dignity, and wellbeing of every worker. This Supplier Code of Conduct and its Compliance Benchmarks apply to all suppliers, manufacturers, subcontractors, and sub-suppliers producing goods or components for Tailgate Tikes LLC, and to all workers in those facilities, including permanent, temporary, agency, contract, piece-rate, salaried, hourly, part-time, night, migrant, and legally employed young workers.

Suppliers are expected to comply with (1) all laws and regulations applicable in the jurisdictions in which workers are employed, (2) this Code, and (3) the Compliance Benchmark standards below. Where these standards differ or conflict, suppliers are expected to comply with the highest applicable standard.

Workplace Code of Conduct

Employment Relationship: Employers shall adopt and adhere to rules and conditions of employment that respect workers and, at a minimum, safeguard their rights under national and international labor and social security laws and regulations.

Nondiscrimination: No person shall be subject to any discrimination in employment, including hiring, compensation, advancement, discipline, termination, or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group, or ethnic origin.

Harassment or Abuse: Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological, or verbal harassment or abuse.

Forced Labor: There shall be no use of forced labor, including prison labor, indentured labor, bonded labor, or other forms of forced labor.

Child Labor: No person shall be employed under the age of 15 or under the age for completion of compulsory education, whichever is higher.

Freedom of Association and Collective Bargaining: Employers shall recognize and respect the right of employees to freedom of association and collective bargaining.

Health, Safety, and Environment: Employers shall provide a safe and healthy workplace setting to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employers' facilities. Employers shall adopt responsible measures to mitigate negative impacts that the workplace has on the environment.

Hours of Work: Employers shall not require workers to work more than the regular and overtime hours allowed by the law of the country where the workers are employed. The regular work week shall not exceed 48 hours. Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. All overtime work shall be consensual. Employers shall not request overtime on a regular basis and shall compensate all overtime work at a premium rate. Other than in exceptional circumstances, the sum of regular and overtime hours in a week shall not exceed 60 hours.

Compensation: Every worker has a right to compensation for a regular work week that is sufficient to meet the worker's basic needs and provide some discretionary income. Employers shall pay at least the minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages, and provide any benefits required by law or contract. Where compensation does not meet workers' basic needs and provide some discretionary income, each employer shall work with Tailgate Tikes LLC to take appropriate actions that seek to progressively realize a level of compensation that does.

I. Law and Code Compliance (L&CC)

L&CC.1 Federal/Country Law. Suppliers shall comply with all relevant and applicable federal and country laws in the jurisdictions in which workers are employed.

L&CC.2 State/Provincial/Local Law. Suppliers shall comply with all relevant and applicable state, provincial, local, and city laws in the jurisdictions in which workers are employed.

II. Employment Relationship (ER)

Employment Management Systems

ER.1 Human Resources. Employers shall have in place written policies and practices and maintain proper and accurate records governing all aspects of employment, from recruitment, hiring, and probation — including written terms and conditions of employment, job descriptions, administration of compensation, and working hours for all positions — through retrenchment and termination processes. Employers shall assign responsibility for human resources administration to clearly defined and adequately qualified staff, and ensure workers at all levels receive communication and training about existing policies and procedures and any revisions. Employers should implement an annual review of all policies and procedures, with input from workers, to ensure they meet legal requirements and this Code.

ER.2 Special Categories of Workers. Employers shall ensure that all legally mandated requirements for the protection or management of special categories of workers — including migrant, juvenile, contract/contingent/temporary, probationary, and pregnant or disabled workers — are implemented. Where local law and this Code differ, the highest applicable standard applies. Home work is prohibited.

ER.3 New Employee Orientation. Employers shall provide an orientation to new employees at the time of hiring covering the employer's rules, compensation package, human resources policies, grievance systems, industrial relations (including respect for freedom of association), workers' rights and responsibilities, this Code, health and safety, and environmental protection. Training shall be updated regularly, particularly when policies are revised, and workers shall be provided written documentation substantiating all issues covered in orientation.

ER.4 Communication. Employers shall inform workers about workplace rules, environmental protection systems, health and safety information, and laws regarding workers' rights with respect to freedom of association, compensation, working hours, and any other legally required information, as well as this Code, through appropriate means, including postings in the local language(s) throughout the workplace's common areas.

ER.5 Supervisor Training. Employers shall ensure that all supervisors are trained in national laws, workplace regulations, this Code, workplace grievance systems, and appropriate compliance practices. Employers shall inform supervisors that they may not use any form of harassment or abuse to maintain labor discipline. Trainings shall be updated regularly.

ER.6 Skills Development Training. Employers shall have written policies and procedures, and implement practices, that encourage ongoing training of all categories of workers with the goal of raising or broadening skills for career advancement. Policies should address how workers are informed of training opportunities, eligibility requirements, whether training is compulsory or voluntary, whether it occurs during or after working hours, and whether training time is compensated.

ER.7 Performance Reviews. Employers shall have written performance review policies and procedures that outline the review steps and process, demonstrate linkage to job grading, prohibit discrimination, are provided in writing, seek written feedback and agreement or disagreement from employees, and follow all local legal requirements. The performance review process shall be communicated to the workforce and reviewed regularly.

ER.8 Promotion, Demotion, and Job Reassignment. Employers shall have written policies and procedures regarding promotion, demotion, and job reassignment that outline the criteria, demonstrate linkage to job grading, prohibit discrimination and the use of demotion or reassignment as a penalty or punishment, are provided in writing, seek written feedback from employees, and follow all local legal requirements.

Recruitment and Hiring

ER.9 Contract, Contingent, or Temporary Workers. Employers shall hire contract, contingent, or temporary workers only where consistent with the national law of the country of production, and shall have written policies and procedures regulating such hiring. Contract, contingent, or temporary workers shall be hired only when: (a) the permanent workforce is not sufficient to meet unexpected or unusually large order volumes; (b) exceptional circumstances would otherwise result in great financial loss to the supplier if delivery cannot be met on time; or (c) the work required falls outside the professional expertise of the permanent workforce.

ER.10 Invalid Use of Contract, Contingent, or Temporary Workers. Employers shall not hire contract, contingent, or temporary workers as a means to support continuing business needs on a long-term basis, and shall not renew contracts for multiple successive short terms in lieu of providing regular employment.

ER.11 Terms for Contract, Contingent, Migrant, or Temporary Workers. Employers must ensure the following minimum terms and conditions: (1) the enterprise defines the job functions or tasks these workers are hired to perform and maintains information on their use in relation to production needs; (2) these workers are provided an employment agreement in their native language setting out employment terms and conditions — for migrant workers, a copy of the contract in their native language shall be provided prior to departure from their country of origin; (3) workplace rules and regulations apply to these workers the same as to permanent workers; (4) national laws governing these workers shall be observed; (5) personnel files and all relevant employment information shall be maintained and accessible at the workplace site at all times; (6) workers hired on more than one occasion for seasonal production shall sign a separate contract for each new hire event, with all relevant information retained in each worker's personnel file; and (7) these workers shall be given priority when the enterprise seeks new permanent employees.

ER.12 Transition to Permanent Employee. For any contract, contingent, or temporary worker who becomes a permanent employee, seniority and other benefits eligibility must be dated from the first date of work as a contract, contingent, or temporary worker, not from the first day of permanent employment.

ER.13 Apprenticeships and Vocational Training. Employers shall comply with all regulations and requirements of apprentice or vocational education programs and shall be able to document that these are legally recognized programs; informal arrangements of any kind are not acceptable. Such programs shall be reserved exclusively for workers who lack the training or experience necessary to be hired as regular workers, and shall be subject to workplace conditions as set by this Code and national laws and regulations.

ER.14 Agreements with Employment Agencies. Employers shall use standard contract language with employment agencies or intermediaries that specifically empowers employers to pay wages directly to migrant, contract, contingent, or temporary workers; ensures equality of compensation and workplace standards under this Code and national law; and specifically prohibits practices that restrict any worker's freedom of movement or ability to terminate their employment.

Termination and Retrenchment

ER.15 Termination Payouts. Employers shall have in place a procedure for determining termination payouts, including methods for correct assessment of payouts for all modes of termination or retrenchment, taking into account national legal requirements. Employers shall establish channels for workers to confidentially express concerns about legally owed payments during a retrenchment process. Employers shall not demand that workers sign any declaration of good health, waiver, or release of rights as a condition of receiving severance pay or other legal benefits, nor threaten to withhold benefits if workers do not sign. Upon termination, severance shall be based on the worker's current salary and seniority calculated from the initial date of hire. Where advance termination payouts are provided as allowed by law, these amounts may be subtracted from the final severance payment but must be included as itemized deductions in the final severance calculation. Where employers provide annual indemnification, original contracts should remain in effect without being terminated.

ER.16 Retrenchment Policies and Procedures. Employers shall maintain proper and accurate records relating to termination and retrenchment. When facing major changes in production, program, organization, structure, or technology likely to result in temporary or permanent layoffs, employers shall communicate alternatives to retrenchment that have been considered and consult any workers' representatives as early as possible with a view to averting or minimizing layoffs. Where layoffs are unavoidable, a plan shall be developed and implemented to mitigate adverse effects on workers and their communities; the plan shall be clearly communicated and posted, with feedback channels for workers. Employers shall give retrenched workers the opportunity to transfer to other owned facilities in the country at a comparable wage and make all efforts to facilitate re-employment in other enterprises in the country.

Grievance System

ER.17 Worker-Management Communication and Grievances. Employers shall have a clear and transparent system of worker-management communication that enables workers to consult with and provide input to management (for example, suggestion boxes, worker committees, designated meeting spaces, union representatives, or meetings between management and workers' representatives). There shall be a mechanism allowing workers to report harassment and grievances confidentially, including concerns about legally owed payments during retrenchment. Employers shall have written procedures allowing direct settlement of grievances between the worker and immediate supervisor, with additional options for senior management review where direct settlement is inappropriate or has failed. Grievance procedures shall be known to workers, who shall be fully trained on their use. Employers shall track the number, types, timing, and resolution of grievances and communicate resolutions to the workforce. Employers shall have a system in place to prevent retaliation against or discrimination toward workers who file grievances, including grievances regarding harassment, abuse, violations of factory procedures, compensation, or unsafe working conditions. Workers may also raise concerns regarding this Code confidentially and without retaliation directly with Tailgate Tikes LLC through the contact information provided with this Code.

Workplace Conduct and Discipline

ER.18 Discipline. Employers shall have written disciplinary rules, procedures, and practices embodying a system of progressive discipline (escalating from verbal warnings to written warnings to suspension and finally to termination). The disciplinary system shall be applied fairly and without discrimination, and shall include management review by someone senior to the manager who imposed the disciplinary action. Employers shall maintain written records of all disciplinary actions and ensure managers and supervisors are fully familiar with the system. Workplace rules, policies, and disciplinary procedures shall be clearly communicated to all workers in the language(s) they speak; any exceptions (for example, immediate termination for gross misconduct such as theft or assault) shall also be in writing and clearly communicated. Workers must be informed in writing when a disciplinary procedure has been initiated against them, have the right to participate and be heard in any disciplinary procedure, and must sign all written records of disciplinary action against them, with records maintained in the worker's personnel file. The disciplinary system shall include a third-party witness during imposition and an appeal process. Employers shall inform workers that any form of harassment or abuse in the workplace is subject to disciplinary measures, and shall commit to non-retaliation for all steps of the disciplinary process, including a worker's request for a witness or appeal.

General Compliance

ER.19 Documentation and Inspection. Employers shall maintain on file all documentation needed to demonstrate compliance with this Code and applicable law, shall make these documents available to third-party assessors commissioned by Tailgate Tikes LLC, and shall submit to inspections without prior notice. All notices legally required to be posted in workplace areas shall be posted.

III. Nondiscrimination (ND)

ND.1 General Compliance. Employers, employment agencies, and intermediaries shall comply with all national laws, regulations, and procedures concerning nondiscrimination. Where local law and this Code differ, the highest applicable standard applies. If not provided by law, employers must provide protection to workers who allege discrimination in any form, including in recruitment and employment practices, compensation, or on the basis of marital or health status.

ND.2 Employment Decisions. All employment decisions shall be made solely on the basis of a person's qualifications — education, training, experience, and demonstrated skills or abilities — as they relate to the inherent requirements of the job. Employment decisions shall not be made on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group, ethnic origin, marital status, or union affiliation or sympathy.

ND.3 Job Advertisements, Descriptions, and Evaluation Policies. Recruitment and employment policies and practices — including job advertisements, job descriptions, application and interview questions, and performance evaluation policies — shall be free from any type of discriminatory bias.

ND.4 Disclosure of Personal Information. Employers may not request the disclosure of any personal, non-job-related information during the application, recruitment, or hiring process, including but not limited to gender, race, religion, disability, sexual orientation, nationality, political opinion, social group, ethnic origin, or marital status.

ND.5 Compensation Discrimination. There shall be no differences in compensation for work of equal value on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group, or ethnic origin.

ND.6 Marital, Partnership, or Family Status. Employers shall not discriminate on the basis of marital, partnership, or family status; shall not threaten workers with dismissal or other adverse employment decisions to prevent them from changing their marital, partnership, or family status (including getting married or becoming pregnant); and shall not make any employment decision that negatively affects a worker's employment status — including dismissal, demotion, loss of seniority, or deduction of wages — on the basis of such status, including pregnancy.

ND.7 Pregnancy Testing. Employers shall not require pregnancy testing of workers except as required by national law, and shall not under any circumstances use pregnancy tests or the use of contraception in hiring or employment decisions, even where pregnancy tests are required by national law.

ND.8 Protection and Accommodation of Pregnant Workers and New Mothers. Employers shall abide by all protective provisions in national laws benefiting pregnant workers and new mothers, including provisions concerning maternity leave and benefits, prohibitions on night work, temporary reassignment away from work stations and environments that may pose risks to pregnant women, their unborn children, or new mothers and newborns, temporary adjustment of working hours during and after pregnancy, and the provision of breastfeeding breaks and facilities. Where such legal protections are lacking, employers shall take all necessary measures to ensure the safety and health of pregnant women and their unborn children, and shall at minimum provide paid leave for regular prenatal and postnatal doctor visits as well as breastfeeding breaks.

ND.9 Health-Related Discrimination. Employers shall not make employment decisions that negatively affect a person's employment status — including recruitment, termination, promotion, or work assignment — on the basis of health status, unless the decision is dictated by the inherent requirements of the job or a medical necessity to protect the worker and/or other workers.

ND.10 Medical Examination. Employers may require routine medical examinations to assess general fitness as a condition of recruitment or continued employment, but such examinations shall not include testing for any disease or illness, such as HIV/AIDS, that does not have an immediate effect on a person's fitness and is not contagious.

ND.11 Confidentiality of Health Status. Employers shall respect the confidentiality of workers' health status and shall not take any action that could breach that confidentiality, including direct or indirect screening (for instance, assessments of risk behavior) or questions about previously taken tests or medications.

ND.12 Reasonable Accommodation for Health Reasons. Employers shall take measures to reasonably accommodate workers with chronic illnesses, including HIV/AIDS-related illnesses, which may include rearrangement of working time, provision of special equipment, rest break opportunities, time off for medical appointments, flexible sick leave, part-time work, and return-to-work arrangements.

ND.13 Reasonable Accommodation, Modifications, and Adjustments. Employers shall make all reasonable modifications and adjustments to accommodate the specific religious, ethnic, gender, and disability-based needs of all workers within the workplace and within any employer-provided facilities such as dormitories or transportation. Workers shall not be required to reimburse the facility for the cost of these accommodations.

ND.14 Dress Codes and Uniforms. Employers shall not impose any discriminatory restrictions on the dress or appearance of workers. Where uniforms or specific clothing are required, accommodations shall be made for religious practice or disability. Any workplace dress code shall not discriminate against or set different standards for ethnic or cultural groups.

ND.15 Spoken Languages. Employers shall not require specific languages to be spoken in the work environment, nor prohibit the use of any language among workers, and shall make every reasonable effort to communicate with workers in their native language.

IV. Harassment or Abuse (H/A)

H/A.1 General Compliance. Employers shall comply with all national laws, regulations, and procedures concerning discipline, violence, harassment, and abuse, including gender-based violence and harassment. If not provided under law, employers must provide protection to workers who allege harassment or abuse violations, and to workers who are victims of domestic violence.

H/A.2 Monetary Fines and Penalties. Employers shall not use monetary fines or penalties to maintain labor discipline, including for poor performance, broken or lost tools or machinery, or violations of company rules, regulations, or policies.

H/A.3 Access to Facilities. Access to food, water, toilets, medical care, health clinics, or other basic necessities shall not be used as a reward or as a means to maintain labor discipline.

H/A.4 Physical Abuse. Employers shall not use any form or threat of physical violence — including slaps, pushes, or other physical contact — as a means to maintain labor discipline.

H/A.5 Verbal Abuse. Employers shall not use any form of verbal violence — including screaming, yelling, or threatening, demeaning, or insulting language — as a means to maintain labor discipline.

H/A.6 Psychological Abuse. Employers shall not use any form or threat of psychological abuse, such as forcing workers to sign letters of self-criticism or posting the names of workers subject to disciplinary measures, as a means to maintain labor discipline.

H/A.7 Freedom of Movement. Employers shall not restrain the freedom of movement of workers — including movement in canteens, during breaks, using toilets, accessing water, or accessing necessary medical attention — as a means to maintain labor discipline.

H/A.8 Elimination of Violence, Harassment, and Abuse. Employers shall ensure that the workplace and all workplace facilities (such as employer-provided transportation or dormitories) are free from any type of violence, harassment, or abuse — physical, sexual, psychological, verbal, or otherwise. Employers, in consultation with worker or union representatives, shall assess specific hazards and risks of harassment and abuse in the workplace, including gender-based violence, arising from working conditions, work arrangements (such as night shifts), work organization, and third parties such as recruitment agencies, contractors, or other intermediaries. Employers shall develop, implement, and monitor policies and procedures for eliminating these risks, including a clear statement that violence, harassment, and abuse will not be tolerated, procedures for investigating allegations, and measures to protect complainants, victims, and witnesses. Employers shall take all necessary precautions to eliminate any action — by the employer, between or among employees, or by third parties retained by the employer or whose work is connected with the workplace — that would result in gender-based violence or harassment, whether occurring inside or outside the workplace or working hours.

H/A.9 Sexual Harassment. Employers shall refrain from: any act of sexual harassment, including inappropriate remarks, insults, jokes, insinuations, or comments on a person's dress, physique, age, or family situation; condescending or paternalistic attitudes with sexual implications that undermine dignity; any unwelcome invitation or request, implicit or explicit, whether or not accompanied by threats; any lascivious look or other gesture associated with sexuality; and any unnecessary physical contact such as touching, caresses, pinching, or assault. Employers shall not offer, or take any action that may suggest an offer of, recruitment, continued employment, promotion, improved working conditions, preferential work assignments, or other preferential treatment in exchange for a sexual relationship. Employers shall not subject workers to prejudicial treatment of any kind in retaliation for refused sexual advances or corrected inappropriate behavior.

H/A.10 Security Practices and Body Searches. All security practices shall be gender-appropriate and non-intrusive so that the dignity of workers is protected when a search is undertaken. Searching of bags and other personal items to prevent theft is acceptable. Body searches and physical pat-downs shall be undertaken only when there is a specific, legitimate reason and with worker consent, unless ordered by a state official with the power to do so. Body searches shall not be undertaken in public, and the person conducting the search shall be of the same sex as the person being searched.

H/A.11 Discipline of Abusive Personnel. Employers shall have a system to discipline supervisors, managers, or workers who engage in any physical, sexual, psychological, or verbal violence, harassment, or abuse — through measures such as compulsory counseling, warnings, demotions, and terminations or a combination thereof — regardless of whether the action was intended as a means to maintain labor discipline, with a view to preventing recurrence and facilitating reintegration into work where appropriate.

V. Forced Labor (F)

F.1 General Compliance. Employers, employment agencies, and intermediaries shall comply with all national laws, regulations, and procedures concerning the prohibition of forced labor and human trafficking. If not provided by law, employers must provide protection to workers who allege forced labor violations.

F.2 Freedom in Employment. All workers shall have the right to enter into and to terminate their employment freely. Employment terms shall be those to which the worker has voluntarily agreed, insofar as those terms do not fall below the provisions of national law, freely negotiated and valid collective bargaining agreements, or this Code. There shall be no employment terms that allow employers, employment agencies, or intermediaries to hold wages already earned, use earned wages as penalties, or in any way punish workers for terminating employment.

F.3 Debt and Bonded Labor. Employers, employment agencies, and intermediaries shall not bind workers to employment as a condition of fulfilling the terms of a debt. Loans may be provided directly to workers only as a component of a larger loan program (for example, housing or education loans) available to all workers. Lending and savings programs must comply with all national laws and regulations. The continuance of a loan may not depend on continued employment at the workplace, and no penalties may be assessed on a loan because a worker ends employment. Interest may not exceed the cost of administering the loan program and any tax liabilities incurred by the program, within legal limits.

F.4 Freedom of Movement. If workplace entrances are locked or guarded to prevent non-employee access for security reasons, workers shall have free egress at all times. No terms imposed by the employer or any employment agency or intermediary shall confine or restrict employees' freedom of movement or free transit.

F.5 Employer-Controlled Residence. Employers shall not require or influence workers to live in employer-owned or employer-controlled residences as a condition of recruitment, continued employment, or receiving the same terms of employment and working conditions as other workers in the same position.

F.6 Freedom of Movement in Employer-Controlled Residences. The freedom of movement of workers who live in employer-owned or employer-controlled residences shall not be unreasonably restricted.

F.7 Threat of Penalty. Employers shall not utilize — nor use employment agencies or intermediaries that utilize — practices that restrict any worker's freedom of movement or ability to terminate employment, or that create a threat of penalty. Examples include, but are not limited to: threats of physical or mental coercion; requiring deposits; imposing financial penalties; requiring workers to pay recruitment and/or employment fees; providing precarious employment; and using false information to recruit workers.

F.8 Forced Overtime. The imposition of overtime where workers are unable to leave the work premises constitutes forced labor.

F.9 Personal Identification and Other Documents. Workers shall retain possession and control of their passports, identity papers, travel documents, work permits, and other personal legal documents.

F.10 Storage of Employee Documents. Employers shall provide, at the employee's request, secure storage for documents such as passports, identity papers, and travel documents. Such storage shall be freely accessible to workers at all times. Employers shall not withhold such documents or restrict workers' access to them for any reason, including to ensure that workers remain in employment.

F.11 Employment Fees. Fees and other costs associated with the employment of workers, including migrant, contingent, contract, and temporary workers, shall be the sole responsibility of the employer. No worker shall pay for a job.

F.12 Free Disposal of Wages. Employers may not limit in any manner the freedom of workers to dispose of their wages. Workers must be free from any coercion to use enterprise- or employer-operated stores.

VI. Child Labor (CL)

CL.1 General Compliance. Employers shall comply with all national laws, regulations, and procedures concerning the prohibition of child labor.

CL.2 Child Labor. Employers shall not employ anyone under the age of 15 or under the age for completion of compulsory education, whichever is higher.

CL.3 Government Permits and Parental Consent Documentation. Where the law requires government permits or parental permission as a condition of employment, employers shall abide by all relevant rules and procedures and shall keep documentation on site for inspection at all times.

CL.4 Employment of Young Workers. Employers shall comply with all relevant laws applying to young workers (those between the minimum working age and 18), including regulations related to hiring, working conditions, types of work, hours of work, proof-of-age documentation, and overtime.

CL.5 Hazardous Work for Young Workers. No person under the age of 18 shall undertake hazardous work — work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety, or morals of persons under 18.

CL.6 Young Worker Identification System. Employers shall have a system for identifying workstations and operations that are inappropriate for young workers according to applicable law.

CL.7 Apprenticeships and Minimum Working Age. Apprentices and vocational students shall not be under the age of 15 or under the age for completion of compulsory education, whichever is higher.

CL.8 Proof of Age Documentation. Employers shall collect and maintain all documentation necessary to confirm and verify the date of birth of all workers, such as birth certificates, and shall take reasonable measures to ensure such documentation is complete and accurate. Where proof-of-age documentation is not readily available or is unreliable, employers shall take all necessary precautions that can reasonably be expected of them to ensure that all workers are at least the minimum working age, including requesting and maintaining medical or religious records or using other means considered reliable in the local context.

VII. Freedom of Association and Collective Bargaining (FOA)

FOA.1 General Compliance. Employers shall comply with all national laws, regulations, and procedures protecting the rights of workers to organize and bargain collectively. Where local law and this Code differ, the highest applicable standard applies. If not provided by law, employers must provide protection to workers who allege violations of freedom of association.

FOA.2 Right to Freely Associate. Workers, without distinction whatsoever, shall have the right to establish and join organizations of their own choosing, subject only to the rules of the organization concerned, without previous authorization. The right to freedom of association begins when a worker seeks employment and continues through the course of employment, including eventual termination, and applies as well to unemployed and retired workers.

FOA.3 Alternative Means of Association. Where the right to freedom of association and collective bargaining is restricted under law, employers shall not obstruct legal alternative means of worker association.

FOA.4 Anti-Union Violence, Harassment, or Abuse. Employers shall not use any form of physical or psychological violence, threats, intimidation, retaliation, harassment, or abuse against union representatives or workers seeking to form, in the process of forming, or who have joined an organization of their own choosing. Such practices shall not be used against workers' organizations or workers participating or intending to participate in formal or informal organizing activities, including strikes.

FOA.5 Anti-Union Discrimination. Employers shall not engage in any acts of anti-union discrimination or retaliation — that is, shall not make any employment decision that negatively affects a worker based wholly or in part on union membership or participation in union activity, including union formation, previous employment in a unionized facility, participation in collective bargaining efforts, or participation in a legal strike. Employers shall not use blocklists to restrict freedom of association.

FOA.6 Restoration of Workers' Rights. Workers who have been unjustly dismissed, demoted, or otherwise suffered a loss of rights and privileges at work due to an act of union discrimination shall, subject to national law, be entitled to restoration of all rights and privileges lost, including reinstatement and retroactive payment of wages, if they so desire.

FOA.7 Protection of Union Representatives. Employers shall comply with all relevant provisions where national law provides special protection to workers or worker representatives engaged in particular union activity (such as union formation) or with particular status (such as founding union members or current union office holders).

FOA.8 Production Shift or Workplace Closure. Employers shall not threaten to shift or shift production, or threaten to close or close a workplace, in an attempt to prevent the formation of a union, in reaction to the formation of a union, in reaction to any other legitimate exercise of the right to freedom of association and collective bargaining (including the right to strike), or in an effort to break up a union. If a workplace is closing and there is a dispute as to whether the closure was intended to prevent or hamper the legitimate exercise of freedom of association, employers shall provide proof assessable by a third party of the validity of the reasons given for closure.

FOA.9 Severance Pay. Employers shall not offer or use severance pay in any form, or under any other name, as a means of contravening the right to freedom of association, including attempts to prevent or restrict union formation or union activity, including strikes.

FOA.10 Employer Interference. Employers shall refrain from any act of interference with the formation or operation of workers' organizations, including acts designed to establish or promote the domination, financing, or control of workers' organizations by employers.

FOA.11 Constitution, Elections, Administration, and Activities. Employers shall not interfere with the right of workers to draw up their constitutions and rules, elect their representatives, or organize their administration and activities.

FOA.12 Registration. Employers shall not attempt to influence or interfere, to the detriment of workers' organizations, with government registration decisions, procedures, or requirements regarding the formation of workers' organizations.

FOA.13 Favoritism. Employers shall not interfere with the right to freedom of association by favoring one workers' organization over another. Where a single union represents workers, employers shall not attempt to influence or interfere in any way with workers' ability to form other organizations that represent workers.

FOA.14 Police and Military Forces. Employers shall not in any way threaten to use, or use, the presence of police or military to prevent, disrupt, or break up any activity that constitutes an exercise of the right to freedom of association, including union meetings, assemblies, and strikes.

FOA.15 Facilities for Worker Representatives. Worker representatives shall have the facilities necessary for the proper exercise of their functions, including access to workplaces and office space where required by law.

FOA.16 Good-Faith Collective Bargaining. Employers shall recognize the right of workers to free and voluntary collective bargaining with a view to regulating terms and conditions of employment by collective agreement. Employers and worker representatives shall bargain in good faith — engaging in genuine and constructive negotiations and making every effort to reach agreement.

FOA.17 Exclusive Bargaining and Other Recognized Unions. Employers shall bargain with any union recognized by law, or by agreement between the employer and that union, as a — or the exclusive — bargaining agent for some or all of its workers, provided such agreement does not contravene national law.

FOA.18 Unorganized Workers. Employers may engage in collective bargaining with representatives of unorganized workers only when no workers' organization exists.

FOA.19 Compliance with Collective Bargaining Agreements. Employers, unions, and workers shall honor in good faith, for the term of the agreement, the terms of any collective bargaining agreement they have agreed to and signed. Worker representatives and workers shall be able to raise issues regarding employer compliance with a collective bargaining agreement without retaliation or negative effect on their employment status. Where a union exists in the workplace, employers shall make a copy of the collective bargaining agreement available to all workers and other interested parties.

FOA.20 Validity of Collective Bargaining Agreements. Collective bargaining agreements that have not been negotiated freely, voluntarily, and in good faith shall be considered not applicable, as shall provisions that contradict national law or offer workers less protection than this Code.

FOA.21 Rights of Minority Unions and Their Members. Unions not recognized as the bargaining agent of some or all workers in a facility shall have the means for defending the occupational interests of their members, including making representations on their behalf and representing them in individual grievances and disciplinary actions, within limits established by applicable law.

FOA.22 Right to Strike. Employers shall not impose any sanction on workers for organizing or having participated in a strike conducted in accordance with ILO standards and jurisprudence.

FOA.23 Replacement Workers. Employers shall not hire replacement workers to prevent or break up a strike conducted in accordance with ILO standards and jurisprudence, or to avoid negotiating in good faith.

VIII. Health, Safety, and Environment (HSE)

HSE.1 General Compliance. Employers shall comply with all national laws, regulations, and procedures concerning health, safety, and the environment.

HSE.2 Document Accessibility. All documents required by applicable law to be available to workers and management — such as health and safety policies, Safety Data Sheets (SDS), and environmental emergency procedures — shall be made available in the prescribed manner, in the local language and in the language spoken by workers if different.

HSE.3 Notification and Record Maintenance. Employers shall notify the relevant national and/or local authorities of all illnesses, accidents, and environmental emergencies as required by applicable law. All illness, safety, accident, and emergency reports shall be maintained on site for at least one year, or longer if required by law.

HSE.4 Permits and Certificates. Employers shall at all times be in possession of all legally required and valid permits and certificates related to health, safety, and environmental issues, including those for: purchase and storage of chemicals; fire safety inspections; machinery inspections; waste disposal; environmental licenses and permits; sanitation (including canteens); and vehicle inspection and driver permits for all employer-provided transportation.

HSE.5 Evacuation Requirements. All applicable, legally required or recommended elements of safe evacuation shall be complied with, including: posting evacuation plans; installation and maintenance of fire alarms; installation and maintenance of emergency lighting; ensuring aisles and exits are not blocked and workers are not blocked within workstations; employee education and training; and evacuation procedures and fire drills. Workers shall be trained in evacuation procedures. Alarm systems shall be regularly tested, and evacuation drills undertaken at least annually. Emergency evacuation procedures shall include notifying local community authorities in the event of accidental discharge or release of chemical or waste products or any other environmental emergency.

HSE.6 Safety Equipment and First Aid Training. All safety and medical equipment (such as firefighting equipment and first aid kits) shall be available in sufficient numbers throughout the workplace, maintained and stocked as prescribed, and easily accessible to workers. A sufficient number of workers shall be trained in first aid and firefighting techniques, upon hire and with periodic refresher training.

HSE.7 Personal Protective Equipment. Workers shall be provided at no cost with all appropriate and necessary personal protective equipment (such as gloves and eye, hearing, and respiratory protection) to effectively prevent unsafe exposure to health and safety hazards, including medical waste.

HSE.8 Use of Personal Protective Equipment. Workers shall be trained in the use and maintenance of personal protective equipment, upon hire and with periodic refresher training. Management shall ensure PPE is used as necessary.

HSE.9 Chemical Management and Training. All chemicals and hazardous substances shall be properly labeled, stored in secure and ventilated areas, and disposed of in a safe and legal manner, in accordance with applicable laws and international standards. Labels shall be in the local language and the language spoken by workers, if different. Workers shall receive training, appropriate to their job responsibilities, on the hazards, risks, and safe use of chemicals and other hazardous substances.

HSE.10 Safety Data Sheets. Safety Data Sheets (SDS) for all chemicals and hazardous substances used in the workplace must be available at the usage and storage sites, in the local language and the language spoken by workers if different, and workers shall have free access to them.

HSE.11 Chemical Protections for Pregnant Women and Young Workers. To prevent unsafe exposure to hazardous chemicals and substances, appropriate accommodations shall be made for pregnant women and workers under 18, as required by applicable law or this Code, in a manner that does not unreasonably disadvantage workers.

HSE.12 Protection of Reproductive Health. Employers shall ensure that women are not engaged in work that constitutes a substantial risk to their reproductive health.

HSE.13 Facility Installation and Maintenance. All necessary ventilation, plumbing, electrical, noise, and lighting services shall be installed and maintained to conform to applicable law and to prevent or minimize hazardous conditions for workers in the facility.

HSE.14 Machinery Safety, Maintenance, and Training. All production machinery, equipment, and tools shall be properly guarded and regularly maintained. Workers shall receive training in the proper use and safe operation of the machinery, equipment, and tools they use. Safety instructions shall be displayed or posted near all machinery or be readily accessible to workers in the language(s) they speak.

HSE.15 Proper Use of Machinery. Employers shall not use negative incentives such as monetary penalty schemes to ensure that workers use machinery, equipment, and tools safely and properly. Instead, training on risk awareness and proper machine use, and positive incentives such as bonuses, should be used.

HSE.16 Refusal to Use Unsafe Machinery. Workers shall not suffer any negative consequences for refusing to work with machinery, equipment, or tools that are not properly guarded or that are reasonably considered unsafe.

HSE.17 Ergonomics. Workstations — including seating and standing arrangements and the reach required to obtain tools — shall be designed and set up to minimize bodily strain. Employers shall train workers in proper lifting techniques, and items such as lifting belts shall be provided.

HSE.18 Medical Facilities. Medical facilities shall be established and maintained as required by applicable law. Medical staff shall be fully licensed and recognized under applicable national rules and regulations, with an appropriate number of medical staff on duty during all working hours, including overtime, as required by national law. An appropriate stock of medical supplies shall be maintained at all times, and expired medicines shall be replaced immediately and disposed of safely.

HSE.19 Sanitation in Workplace Facilities. All facilities — including workplace buildings, toilets, canteens, kitchens, and clinics — shall be kept clean and safe and shall comply with all applicable laws, including relevant sanitation, medical, and safety and health regulations.

HSE.20 Toilets. Employers shall provide the number of toilets required under applicable law within reasonable distance of the workplace, and should also consider the number of workers, privacy for each individual and gender, accessibility, and hygiene.

HSE.21 Toilet Restrictions. Employers shall not place any undue restrictions on toilet use in terms of time or frequency.

HSE.22 Food Preparation. All food made available to workers shall be prepared, stored, and served in a safe and sanitary manner in accordance with all applicable laws and international standards. All workers handling food must be trained and/or certified to prepare or serve food in the facility.

HSE.23 Drinking Water. Safe and clean drinking water shall be freely available at all times within reasonable distance of the workplace, at a reasonable temperature, with safe and sanitary means to drink (such as cups) available in appropriate numbers.

HSE.24 Drinking Water Restrictions. Employers shall not place any undue restrictions on access to drinking water in terms of time or frequency.

HSE.25 Dormitory Facilities. Dormitory facilities, including those provided by employment agencies or intermediaries associated with the employer, shall meet all applicable laws and regulations related to health, safety, and environment, including fire safety, sanitation, risk protection, and electrical, mechanical, and structural safety. All dormitories shall be kept secure and clean and shall have safety provisions such as fire extinguishers, first aid kits, unobstructed emergency exits, and emergency lighting. Emergency evacuation drills shall be conducted at least semi-annually.

HSE.26 Dormitories Separate from Production. All dormitory facilities must be structurally sound, in good repair, and located separately from production, warehouse, and hazardous chemical storage areas.

HSE.27 Childcare Facilities and Children on Premises. Childcare facilities shall not physically overlap with production areas, and children shall not have access to production areas. Children under the minimum working age shall not be allowed in workplace areas at any time, except as part of a guided school tour or similar unusual event. All childcare workers must be fully trained and licensed to provide the level of care necessary; where local legal requirements are absent, childcare workers must have at least some vocational training in childcare. Childcare facility hours must match the working hours of the facility's shift schedule, following any requirements of local law.

HSE.28 External Contractors. Employers shall create a system to ensure that all necessary health and safety protections are provided for external contractors, including protection when working within confined spaces, during maintenance work, and for general health and safety.

HSE.29 High-Risk Areas. Employers shall provide all necessary protection for workers when working at heights, in confined spaces, or in other high-risk areas.

HSE.30 Health, Safety, and Environmental Management System. Employers shall develop, maintain, and regularly review health, safety, and environmental policies to ensure compliance with all national laws, regulations, and this Code. These policies shall contain the framework for a comprehensive health, safety, and environmental management system, including an HS&E risk assessment, within which the following are clear and regularly tested and reviewed: employers' responsibilities; workers' rights and duties; responsibilities of designated personnel; procedures enabling workers to raise health, safety, and environmental concerns; procedures for reporting death, injury, illness, near-miss accidents, and environmental emergencies; protection of workers who allege health, safety, or environmental violations; and root-cause analysis of workplace accidents with proactive action to prevent recurrence. Environmental policies shall include procedures to minimize environmental impacts with respect to energy, air emissions, water use and wastewater, waste, hazardous materials, and other significant environmental risks, and to pursue continuous improvement in environmental performance.

IX. Hours of Work (HOW)

HOW.1 General Compliance. Employers shall comply with all national laws, regulations, and procedures concerning hours of work, public holidays, and leave. If not provided by law, employers must provide protection to workers who allege violations of laws governing work hours.

HOW.2 Rest Day. Workers shall be entitled to at least 24 consecutive hours of rest in every seven-day period. If workers must work on a rest day, an alternative consecutive 24 hours of rest must be provided within that same seven-day period or immediately following it.

HOW.3 Meal and Rest Breaks. Employers shall provide reasonable meal and rest breaks, which at a minimum must comply with national law.

HOW.4 Protected Workers. The workplace shall comply with all applicable laws governing work hours that regulate or limit the nature, frequency, and volume of work performed by women or by workers under the age of 18.

HOW.5 Protected Worker Record Keeping. Employers shall maintain the records necessary to identify all women workers and all workers under 18 entitled to legal protections concerning work hours.

HOW.6 Reasonable Staffing Levels. Employers' personnel practices shall demonstrate an effort to maintain a level of staffing that is reasonable in view of predictable or continuing fluctuations in business demand.

HOW.7 Averaging of Regular Hours. Employers may calculate regular hours of work as an average over a period longer than one week only where national law provides for that possibility and all formal and procedural requirements attached to such calculation (for instance, official permission from the relevant authorities or limits on the calculation period) are met. The basis for such calculation shall not exceed 48 hours per week.

HOW.8 Forced Overtime. Employers shall not require or permit workers to work more than the overtime hours allowed by the law of the country where the workers are employed. All overtime work shall be consensual, and employers shall operate a voluntary overtime system, including for overtime used in exceptional circumstances.

HOW.9 Exceptional Circumstances. Employers shall be able to explain all periods when the exceptional-circumstances exception has been used, and shall take reasonable steps to inform workers about the nature and expected duration of the circumstances sufficiently in advance to allow workers to make alternative plans.

HOW.10 Public Holidays. Employers shall provide workers with all official public holidays as required under national law. If not prohibited by local law, any replacement of official holidays with alternative days off must be voluntary and agreed upon in writing by the worker in advance. When using replacement holidays, all legal and Code requirements regarding overtime and hours of work apply.

HOW.11 Annual Leave. Employers shall provide workers with paid annual leave as required under national law. Even where national law allows employers to pay extra compensation in lieu of paid annual leave, employers shall not utilize that option.

HOW.12 Annual Leave Determination. Employers shall not impose undue restrictions on workers' use of annual leave. The timing of annual leave shall be determined by employers in consultation with workers, taking into account work requirements and workers' opportunities for rest and relaxation.

HOW.13 Annual Leave Procedures. Any workplace procedures regulating the timing of annual leave (for example, minimum service periods or advance written requests) must be in line with national law and communicated in full to all workers.

HOW.14 Annual Leave Wage Payments. Employers shall pay workers taking annual leave their normal or average wages for the full leave period in advance, unless specified differently under national law.

HOW.15 Retaliation for Taking Leave. Employers shall not impose any sanction on workers for requesting or taking any type of leave — such as annual, sick, or maternity leave — in line with all applicable rules and procedures.

HOW.16 Sick Leave. Employers shall provide workers with sick leave as required under national law.

HOW.17 Sick Leave Restrictions. Employers shall not impose undue restrictions on sick leave. Any procedures regulating sick leave (for example, prompt notification or medical certificates) must be in line with national law and communicated in full to all workers.

HOW.18 Calculation of Absences. Absences from work for reasons beyond workers' control, such as sick leave or periods when workplace operations are suspended, shall not be counted as annual leave nor deducted from length-of-service calculations, unless specified differently under national law.

HOW.19 Suspension of Work. Employers may suspend work only in accordance with national law. Workers shall be paid in full during periods of suspension unless national law stipulates otherwise, workers and their representative organizations agree otherwise, or the relevant national authorities authorize an alternative arrangement. Conditions of suspension shall be communicated in full to all workers.

HOW.20 Excessive Hours Reduction. Employers shall conduct regular analysis of hours of work in their workplaces and maintain procedures demonstrating a commitment to progressively reducing excessive hours of work.

HOW.21 Overtime Hours. Other than in exceptional circumstances, total weekly work hours (regular hours plus overtime, including any alternative shift patterns such as 4x4 or 3x3) shall not exceed 60 hours per week.

HOW.22 Time Recording System. Employers shall have policies for managing all working hour, overtime, and leave records in normal and exceptional circumstances. Accurate time records — including overtime, breaks, and leave — shall be maintained. Time worked by all workers, regardless of wage system, shall be fully documented by timecards or other mechanical or electronic recording systems. Employers shall not maintain multiple time-keeping systems or records; time records shall be authentic and accurate. If not provided by law, employers must provide protection to workers who allege the existence of multiple time-keeping systems or falsification of work-time records.

X. Compensation (C)

C.1 General Compliance. Employers shall comply with all national laws, regulations, and procedures concerning the payment of compensation to workers. Where differences or conflicts between national law and this Code arise, employers are expected to apply the highest standard. Where national law does not address the payment of compensation, employers shall follow the standards in this Code.

C.2 Minimum Wage. Employers shall pay workers at least the legal minimum wage or the prevailing industry wage, whichever is higher, for regular working hours (not including overtime). Workers shall be informed about the legal minimum wage.

C.3 Probationary Workers. Where probationary employment is legally allowed, probationary workers shall receive at least the minimum wage for regular workers or the prevailing industry wage for regular workers, whichever is higher, and all legally mandated benefits. No worker shall work more than three months in probationary status.

C.4 Apprentices and Vocational Trainees. During the training period, apprentices and vocational trainees shall receive at least the minimum wage for regular workers or the prevailing industry wage, whichever is higher, and all legally mandated benefits. If local law allows a lower minimum wage for apprentices or trainees, the lower wage may be applied only for the first 30 days, and only if that time is dedicated primarily to training rather than production or other essential tasks.

C.5 Contract, Contingent, or Temporary Workers. Contract, contingent, migrant, and temporary workers shall receive at least the minimum wage for regular workers or the prevailing industry wage, whichever is higher; all legally mandated benefits; and at least the same compensation as regular workers performing the same job functions or tasks with similar levels of experience or seniority.

C.6 Timely and Direct Payment of Wages. All wages, including payment for overtime, shall be paid directly and in full within legally defined time limits. Where no time limits are defined by law, compensation shall be paid at least once a month.

C.7 Accurate Calculation, Recording, and Payment. All payments to all workers — including hourly wages, piecework, benefits, and other incentives — shall be calculated, recorded, and paid accurately.

C.8 Accurate Length-of-Service Calculation. All workers shall be credited with all time worked for an employer for purposes of calculating length of service and determining the benefits to which they are entitled.

C.9 Overtime Payments. Employers shall compensate workers for all hours worked. The facility shall comply with all applicable laws, regulations, and procedures governing premium rates for work on holidays, rest days, and overtime. Employees shall be compensated for overtime hours at the premium rate legally required in the producing country; where no legal overtime premium exists, employees shall be compensated at the prevailing industry premium rate or the internationally recognized overtime rate, whichever is higher.

C.10 Overtime Wage Awareness. Workers shall be informed, orally and in writing and in the language(s) they speak, about overtime wage rates prior to undertaking overtime.

C.11 Nonpayment of Incentives. Regardless of any production quota, incentives shall not be reduced or withheld if the result would be wages below the legal minimum wage or the prevailing industry wage, whichever is higher.

C.12 Deposit of Legally Mandated Deductions. All legally mandated deductions for taxes, social insurance, or other purposes shall be deposited as required. Employers shall not hold over any of these funds from one pay period to another unless the law specifies that deposits are to be made less frequently than pay periods. If the law does not specify, deposits shall be made before the next pay period in all cases.

C.13 Voluntary Wage Deductions. Voluntary wage deductions — including for savings clubs, loan payments, and union dues or fees — may be made only with the express written consent of individual workers, unless (in the case of union dues and fees) specified otherwise in a freely negotiated and valid collective bargaining agreement, and in all cases must fall within the limits and conditions specified by law. Written consent shall be documented in employee files. All voluntary deductions shall be credited to the proper accounts, and employers shall not hold funds illegally or inappropriately.

C.14 Access to Deduction Information. Workers shall have access to regular and full information concerning the status of the relevant accounts and the status and level of their payments into them.

C.15 Pay Statement. Employers shall provide workers a pay statement, in a language workers understand, each pay period and not less than once a month, showing: earned wages, wage calculations, total hours worked, regular and overtime pay, bonuses, all deductions, and the final total wage.

C.16 Compensation Receipt. All compensation records — wages and benefits, whether in cash or in kind — must be properly documented, with receipt and accuracy confirmed by the relevant worker in writing (for example, by signature or thumbprint). No one may receive wages on behalf of a worker unless the worker has, in full freedom, authorized another person in writing to do so.

C.17 Record Maintenance. Employers shall ensure that all legally required payroll documents, journals, and reports are available, complete, accurate, and up to date.

C.18 False Payroll Records. Employers shall not use hidden or multiple payroll records to hide overtime, to falsely demonstrate hourly wages, or for any other fraudulent purpose. Payroll records shall be authentic and accurate.

C.19 Worker Awareness and Understanding of Compensation. Employers shall make every reasonable effort to ensure workers understand their compensation, including the calculation of wages, incentive systems, benefits, and the bonuses to which they are entitled at the workplace and under applicable law, and shall communicate all relevant information orally and in writing in the local language or the language spoken by workers, if different.

C.20 Employer-Provided Benefits. All workers have the right to use or not use services provided by employers, such as housing or meals. Deductions for services shall not exceed the cost of the service to the employer, and employers must be able to demonstrate the accuracy or reasonableness of these deductions.

C.21 Legally Mandated Benefits. Employers shall provide all legally mandated benefits — including holidays, leave, bonuses, severance payments, and 13th-month payments — to all eligible workers within legally defined time periods, and all benefits shall be calculated correctly.

C.22 Compensation Disputes. Employers must establish a system through which workers can dispute compensation and receive clarification in a timely manner.

C.23 Fair Compensation and Basic Needs. Where compensation for a regular workweek is not sufficient to meet workers' basic needs and provide some discretionary income, each employer shall work with Tailgate Tikes LLC to take appropriate actions that seek to progressively realize a level of compensation that does.

C.24 Piece Rates and Minimum Wage. Employers shall not set production targets, piece rates, or any other incentive or production system at a level requiring workers to work beyond the regular working hours set by this Code (excluding overtime) in order to earn at least the minimum wage or the prevailing industry wage, whichever is higher. Employers shall not set production targets, piecework, or any other incentive or production system at a level where payment for overtime work performed is less than the premium pay required by law or this Code.

C.25 Wage Advances. Wage advances shall not exceed three months' pay or legal limits, whichever is less. Advances shall be made only under clearly established rules communicated to workers, must be properly documented, and their receipt and accuracy must be confirmed by the relevant worker in writing. No interest may be charged on wage advances.

XI. Ethics and Anti-Corruption (E)

E.1 Anti-Bribery and Corruption. Suppliers shall not offer, promise, give, request, or accept bribes, kickbacks, facilitation payments, or any other improper payments or advantages, whether dealing with public officials or private parties, and shall comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act.

E.2 Gifts and Hospitality. Suppliers shall not offer gifts, hospitality, or entertainment to Tailgate Tikes LLC personnel, agents, or auditors intended to improperly influence a business decision, an audit result, or a compliance finding.

E.3 Accurate Books and Records. Suppliers shall maintain accurate and transparent books, records, and business documentation, including all records relevant to demonstrating compliance with this Code, and shall not falsify any record or misrepresent any condition or practice, including in connection with audits or assessments. Coaching workers on how to answer auditor questions is prohibited.

E.4 Conflicts of Interest. Suppliers shall disclose to Tailgate Tikes LLC any actual or potential conflict of interest involving Tailgate Tikes LLC personnel or their family members.

XII. Responsible Sourcing, Traceability, and Import Compliance (RS)

RS.1 Supply Chain Traceability. Suppliers shall maintain documentation sufficient to trace the origin of materials used in Tailgate Tikes LLC products through the supply chain, including fiber and raw material origin, yarn spinning, fabric production, and finished goods assembly, and shall provide such documentation to Tailgate Tikes LLC upon request.

RS.2 Forced-Labor Import Compliance. Suppliers shall not source materials, components, or labor — at any tier of the supply chain — that are mined, produced, or manufactured wholly or in part with forced labor, and shall comply with all applicable forced-labor import laws, including Section 307 of the U.S. Tariff Act of 1930 and the Uyghur Forced Labor Prevention Act (UFLPA). Suppliers shall not source materials or inputs from entities on the UFLPA Entity List and shall cooperate fully and promptly with any documentation request from Tailgate Tikes LLC or from customs authorities relating to import compliance, including requests arising from a detention, exclusion, or inquiry.

RS.3 Material Disclosure. Suppliers shall accurately disclose the fiber content, material composition, and country of origin of all products and components supplied to Tailgate Tikes LLC, and shall promptly notify Tailgate Tikes LLC of any change in material sourcing, upstream suppliers, or production location before implementing the change.

RS.4 Product Safety Cooperation. Suppliers shall produce goods in accordance with the product specifications, applicable U.S. consumer product safety requirements, and testing protocols communicated by Tailgate Tikes LLC, and shall cooperate fully with third-party product safety testing, tracking-label requirements, and documentation supporting Children's Product Certificates.

XIII. Subcontracting (SUB)

Tailgate Tikes LLC does not permit subcontracting without our prior written approval. All salesman-sample and bulk production orders must be placed within facilities that have been pre-approved by Tailgate Tikes LLC, without exception. Direct suppliers are required to continuously monitor approved subcontractors and sub-suppliers for social compliance using standards that meet or exceed this Code and these Benchmarks. The requirements of this Code apply to the whole supply chain, including approved sub-suppliers and subcontractors. Standards apply equally to permanent, temporary, and agency workers, as well as piece-rate, salaried, hourly, legally employed young workers, part-time, night, and migrant workers.

SUB.1 Subcontractor Compliance. Management shall require that subcontractors in the supply chain uphold this Code. Management shall provide all documentation supplied by Tailgate Tikes LLC to all subcontractors contracted for longer than 30 days, whether consecutive or non-consecutive, within one calendar year. Management shall provide information regarding all subcontractors to Tailgate Tikes LLC upon return of the signed acknowledgment of this Code; if additional subcontractors are engaged at a later date, management is required to disclose information about the subcontractor within 10 days of the contract date. If Tailgate Tikes LLC determines that a subcontractor is not abiding by this Code, Tailgate Tikes LLC has the right to cancel production of any goods sold to Tailgate Tikes LLC produced by the non-compliant subcontracting facility.

SUB.2 Consequences of Noncompliance. Failure to comply with these subcontracting requirements may result in termination of the supplier relationship.

XIV. Code Communication and Training (COM)

All suppliers are required to (1) post this Code in a conspicuous place frequented by all employees, in the local languages spoken by employees, supervisors, and managers, and (2) undertake annual, documented training to educate current and new employees about the Code standards.

COM.1 Posting. Employers shall post the Tailgate Tikes LLC Code of Conduct in a prominent place, in the local languages spoken by employees and managers.

COM.2 Annual Training. Employers shall conduct, and document in writing, annual training on the Tailgate Tikes LLC Code standards for all current employees.

COM.3 New Hire Training. Employers shall conduct, and document in writing, training on the Tailgate Tikes LLC Code standards for all new employees upon hire.

XV. Monitoring, Remediation, and Enforcement (MRE)

MRE.1 Right to Assess. Tailgate Tikes LLC and third-party assessors commissioned by Tailgate Tikes LLC may conduct announced or unannounced assessments of any facility producing goods for Tailgate Tikes LLC, including document review, facility walkthroughs, and confidential worker interviews. Suppliers shall provide full access and shall not retaliate against any worker for participating in an assessment or raising a concern.

MRE.2 Corrective Action. Where an assessment identifies noncompliance with this Code, the supplier shall develop and implement a corrective action plan with defined responsibilities and timelines, subject to Tailgate Tikes LLC review. Tailgate Tikes LLC's preferred approach is remediation: working with suppliers to correct issues and improve conditions rather than immediately terminating the relationship.

MRE.3 Zero-Tolerance Violations. Notwithstanding MRE.2, the following constitute zero-tolerance violations that may result in immediate suspension of orders or termination of the supplier relationship: child labor; forced labor or human trafficking; physical abuse; unauthorized subcontracting; falsification of records or audit fraud; bribery of auditors or Tailgate Tikes LLC personnel; and imminent, serious threats to worker life or safety.

MRE.4 Reporting Concerns. Workers, suppliers, and third parties may report suspected violations of this Code confidentially to Tailgate Tikes LLC through the contact information provided with this Code. Tailgate Tikes LLC prohibits retaliation against anyone who reports a concern in good faith.

Glossary of Terms

Applicable Facilities: All facilities producing goods or components for Tailgate Tikes LLC, including facilities operated by direct suppliers and by approved subcontractors and sub-suppliers.

Basic Needs: The minimum necessary for a worker and two dependents to have access to resources including food, safe drinking water, clothing, shelter, energy, transportation, education, sanitation facilities, access to health care services, and other essential needs, including provisions for unexpected events. Where internationally recognized living wage benchmarks are available (such as the regionally specific Anker research methodology), a more specific family size is utilized.

Benefit: Remuneration in cash or in kind, in addition to payment for work done. This takes the form of holidays or leave with pay, social security benefits, medical care, health services, various allowances and bonuses, and housing, educational, or recreational facilities. Additional benefits may be granted by the employer, either on their own initiative or as a result of collective bargaining. Not all legally mandated benefits or contributions can be included when evaluating workers' compensation against internationally recognized living wage benchmarks.

Compensation: Total remuneration, in cash and in kind, payable by the employer to an employee in return for work done during a specific pay period. Compensation has two main components: wages and salaries payable in cash and/or by direct or electronic deposit, and the amount of benefits payable by the employer.

Discretionary Income: The remaining income of a worker after taxes, legal deductions, and basic-needs expenses.

Exceptional Circumstances: Events or circumstances that substantially disrupt production and that are out of the ordinary and out of the control of the employer, including earthquakes, floods, fires, national emergencies, force majeure, or periods of prolonged political instability. This definition does not include peak production periods, which can be planned for, or holidays or seasonal fluctuations.

Employees: All men and women directly employed or contracted by an employer, including executives, managers, supervisors, and workers.

Employer: A person or institution with the authority to sign contracts, including employment contracts, and to hire and dismiss persons in the workplace. Employers offer wages or a salary to workers in exchange for work or labor. Employers are responsible for implementing this Code in applicable facilities.

Employment Agency: Any person or entity, independent of the public authorities, that provides services for matching offers of and applications for employment and other services relating to job seeking, such as the provision of information, or that employs workers with a view to making them available to a third party.

Employment Decision: Includes hiring; termination; job security; job assignment; compensation; promotion; downgrading; transfer; vocational training; discipline; and assignment of work and conditions of work, including hours of work, rest periods, and occupational safety and health measures.

Employment Fees: All costs associated with the recruitment, compensation, training, and ongoing employment of a worker, which may include, but are not limited to: recruitment fees and related costs, as well as illegitimate costs, legal filing fees, registration fees, social security, training costs, health examination costs, and personal protective equipment costs.

Human Trafficking: Recruitment, transportation, harboring, or receipt of people for the purposes of slavery, forced labor (including bonded labor or debt bondage), or servitude.

Internationally Recognized Overtime Rate: The internationally recognized rate of pay for work beyond regular hours. ILO Convention 30, Hours of Work (Commerce and Offices) Convention, Article 7.4, establishes such rate at no less than one and one-quarter times the regular rate.

International Standards: Practices and requirements recommended by relevant international industry associations, health and safety organizations, or intergovernmental bodies, such as the ILO, OECD, UN, and international hazard communication standards.

Management: Person or persons appointed by the owners or directors of an applicable facility to supervise or manage its operations.

Piecework: A method of wage payment based solely on the number of units produced, or any work for which piece rates are paid.

Piece Rate: A predetermined amount paid per unit of output to workers executing piecework.

Precarious Employment: A work arrangement in which employment security, considered one of the principal elements of the labor contract, is lacking. This term encompasses temporary and fixed-term labor contracts, home workers, contract workers, and contingent workers.

Retrenchment: The permanent dismissal of an employee or employees in order to reduce the workforce.

Wage: Payment made for work performed.

Legal Requirements on Wages: All laws and regulations, national and local, concerning wages, including but not limited to: full and on-time payment of wages for regular and overtime work; provision of benefits, including paid holidays; payment of social security contributions; payment of legal taxes and deductions; and compliance with prohibitions on discrimination in wage setting and payment practices.

Minimum Wage: The minimum wage level established by national or local law for a regular worker.

Net Wage: When evaluating workers' compensation against internationally recognized living wage benchmarks, the worker's net wage includes the basic or contracted wage and benefits, minus mandatory taxes and legal deductions. Leave pay may be included when it is not already included in the basic or contracted wage. Incentive pay may be included when it is earned by all workers during the regular work week. Overtime pay and social security contributions are not included in the worker's net wage.

Prevailing Wage: The level of wage generally paid in the relevant country or region for work in the same sector and for comparable levels of responsibility and experience.

Worker: All non-management personnel working at an applicable facility.

Apprentice: A worker who is part of an official, legally recognized apprenticeship or vocational training program.

Contingent Worker: Also known as a casual worker. A person who works occasionally and intermittently, employed for a specific number of hours, days, or weeks.

Contract Worker: Labor supplied by a third-party employment agency.

Home Worker: A person who carries out work in their home or in other premises of their choice, other than the workplace of the employer, for a fixed wage or piece rate, resulting in a product or service as specified by the employer, irrespective of who provides the equipment, materials, or other inputs used. Tailgate Tikes LLC does not permit the use of home work or home workers in its supply chain, regardless of local law provisions.

Migrant Worker: A person who migrates or has migrated from one country to another — or, in some cases, between regions or provinces of a country — with the specific purpose of exercising an economic activity from which they will receive a wage.

Regular Worker: A person with a permanent, full-time position in the facility.

Special Category of Worker: Workers who are not permanent or not local, who are in a probationary role, who have special needs on a temporary or permanent basis (for example, pregnant, juvenile, or disabled workers), or who fall outside the formal workplace environment (for example, home workers).

Temporary Worker: A person with a labor contract of limited or unspecified duration with no guarantee of continuation.

Young Workers: Persons between the minimum working age and the age of 18.

Supplier Acknowledgment

Each supplier producing goods for Tailgate Tikes LLC is required to review this Code, communicate it to its workforce and approved subcontractors, and return a signed acknowledgment confirming its commitment to comply with the Code and these Compliance Benchmarks. Questions about this Code, and confidential reports of suspected violations, may be directed to Tailgate Tikes LLC through our Contact Us page.