California Supply Chain Transparency Law

In our home turf of California, on January 1, 2010, the California Transparency in Supply Chains Act of 2010 (SB 657) (“Act”) went into effect to provide consumers with the information they need to make informed choices about the goods and services they buy and the companies they support. The Act seeks the elimination of slavery and human trafficking from product supply chains.

As proud Californians and Global citizens, we here at Zazzle are committed to ensuring that our company and the companies we work with are free from forced labor. This means we’re taking a stand on a few key measures as follows:

· We work with a large, diverse chain of stakeholders and business partners and we expect them to adhere to ethical business practices consistent with our own.

· As a responsible corporate citizen, we seek to ensure that quality and safety standards are maintained throughout our supply chain by well-treated, fairly compensated workers in accordance with all applicable laws.

· We maintain internal accountability standards for our suppliers and assess them on an annual basis using Zazzle and third party resources, including onsite inspections (both scheduled and unannounced).

· We also require our suppliers to certify they are in compliance with all applicable laws.

· We train our Zazzle employees involved in our supply chain on these issues, and will terminate business with any supplier found to have violated this policy.

· We believe in sharing these measures as a way of honoring the efforts of this act and our own commitment to a product free from forced labor.

Code of Conduct

Zazzle Inc. (“Zazzle”) and its partners, suppliers and contractors (collectively with Zazzle, “We” or “our”) believe that our first responsibility is to our people. In keeping with this belief, We are committed to treating employees fairly, with dignity and respect, and We pledge to ensure ethical and responsible conduct in all of our operations. As part of our pledge, We believe in doing business with partners, suppliers and contractors who share this commitment and who will, at a minimum, both comply with this Code of Conduct and maintain full compliance with all federal, state and local laws, standards, rules and regulations.

EMPLOYMENT RELATIONSHIP:
We 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. We shall conduct all business in an ethical manner and shall not seek to gain competitive advantage by means of unethical or dishonest practices. All of our business will be conducted with utmost integrity and trustworthiness.

FORCED LABOR:
We shall use no forced labor, including prison labor, indentured labor, bonded labor, or any other forms of forced labor. We shall comply with international standards and all applicable local and national laws, regulations, standards, and procedures concerning the prohibition of forced labor and human trafficking, such as the California Transparency in Supply Chains Act and related sections of the Dodd-Frank Act (including Section 1502, which addresses products containing “conflict minerals”).

CHILD LABOR:
We shall only employ workers who are at least the highest of the following ages: (i) the age of 15 (or 14 where, consistent with International Labor Organization practices for developing countries, the law of the country of manufacture allows such exception); (ii) the age for completion of compulsory education; or (iii) the local minimum age for employment. No person under the age of 18 shall undertake hazardous work (i.e., work which, by its nature or the circumstances in which it is carried out, is likely to cause harm to the health or safety of such person). We shall work with governmental organizations, human rights, and NGOs, as determined by Zazzle and its licensors, to minimize the negative impact on any child released from employment as a result of the enforcement of this Code of Conduct.

HARASSMENT OR ABUSE:
We shall treat every employee with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse. We shall neither use nor tolerate any form of corporal punishment.

NONDISCRIMINATION:
We shall not discriminate against any person in employment matters (including hiring, compensation, advancement, discipline, termination or retirement) on the basis of gender (e.g., gender expression, gender identity, sexual orientation, pregnancy, race (e.g., nationality, ancestry, social or ethnic origin, citizenship), religion, age, political opinion, physical or mental disability (e.g., medical condition (cancer-related or genetic characteristics), genetic information including family medical history), marital status, or service in the uniformed services, and shall act in compliance with state and federal regulations.

HEALTH, SAFETY & ENVIRONMENT:
We shall provide employees with a safe and healthy workplace setting (i) 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 our facilities, in compliance with all laws, regulations or standards applicable to our business, and (ii) with working conditions that do not pose a risk of serious harm, that are free of known dangers and/or serious recognized hazards. In the event of any conflict between the provisions of any of the aforementioned applicable laws, regulations or standards, We shall apply the higher standards. We shall find and correct safety and health problems, and try to eliminate or reduce hazards in the working environment. We shall ensure, at a minimum, (i) reasonable access to potable water and sanitary facilities, (ii) fire safety, and (iii) adequate lighting and ventilation. Additionally, We shall adopt responsible measures to mitigate negative impacts that the workplace has on the environment.

WHISTLEBLOWER PROTECTION:
We shall ensure that our employees are able to use their rights under the law to either report or refuse to participate in activities or conditions that would result in a violation of a state or federal statute, rule or regulation, without retaliation and discrimination. We shall not make, adopt or enforce any rule, regulation or policy preventing an employee from being a whistleblower. We shall not retaliate against an employee for having exercised their rights under the law.

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING:
We shall recognize and respect the right of employees to freedom of association and collective bargaining with bargaining representatives of their own choice in accordance with International Labour Organisation Convention 87, which protects freedom of association and the right to organize. No employees shall be subject to harassment, intimidation or retaliation as a result of their efforts to freely associate or bargain collectively. We shall allow union organizers reasonable access to employees and must recognize the union of the employees’ choice.

HOURS OF WORK:
Except in extraordinary business circumstances, our hourly and/or quota-based wage employees shall (i) not be required to work more than the lesser of (a) 48 hours per week and 12 hours overtime or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture or, where the laws of such country do not limit the hours of work, the regular work week in such country plus 12 hours overtime; and (ii) be entitled to at least 24 consecutive hours of rest in every 7-day period. We shall ensure that any piece-rate quotas are adjusted to what can reasonably be accomplished during an 8-hour period. All overtime work shall be consensual. We shall not request overtime on a regular basis and shall compensate all overtime work at a premium rate as is legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate at least equal to their regular hourly compensation rate.

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. We 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 fringe benefits required by law or contract. Where compensation does not meet workers’ basic needs and provide some discretionary income, We shall work with Zazzle and/or the FLA, as appropriate, to take appropriate actions that seek to progressively realize a level of compensation that does.

EQUAL RIGHTS:
We believe that assuring and safeguarding equal rights is of particular importance, and so, in addition to the safeguards detailed above, shall abide by the following specific guidelines:

1. All workers will receive equal remuneration, including benefits, equal treatment, equal evaluation of the quality of their work, and equal opportunity to fill all positions regardless of gender or any other protected classes;

2. Pregnancy tests will not be a condition of employment, nor will they be demanded of employees. Workers will not be forced or pressed to use contraception;

3. We shall provide, and ensure that our subcontractors provide, appropriate services and accommodations to female workers in connection with pregnancy. Workers who take maternity leave will not face dismissal nor threat of dismissal, loss of seniority or deduction of wages due to pregnancy, and will be able to return to their former employment at the same rate of pay and benefits; and

4. Female workers will not be exposed to conditions that endanger their reproductive health (e.g., exposure to hazards, including glues and solvents that may endanger their safety), unless thorough protections are in place.

ANTI-CORRUPTION:
We shall comply with all laws, rules and regulations governing bribery and corruption in all countries in which we do business. Any gifts and/or entertainment given or received by us (including company officers and senior leadership) must (i) be in compliance with law, (ii) not violate the giver’s and/or receiver’s policies on the matter, and (iii) be consistent with local custom and practice. We do not solicit gifts, entertainment, or favors of any value from persons or firms with which we do or may potentially do business. We never act in a manner that could cause any vendor or customer to feel obligated to make a gift, provide entertainment, or provide personal favors in order to do or continue to do business with us.

IN ADDITION TO THE CODE OF CONDUCT PROVISIONS ABOVE:
We confirm that: (i) We have informed our employees about the workplace standards both orally and through the posting of standards in a prominent place, and have undertaken other efforts to educate employees about the standards on a regular basis; (ii) We have not utilized any subcontractors without first notifying Zazzle; and (iii) as a supplier to Zazzle, We will be subject to periodic compliance audits by their monitors or external monitors with whom Zazzle contracts, and agree to allow them to enter our facility(ies) to interview managers and workers, review company records and inspect factory and dormitory buildings.