Supply Chain Code of Conduct

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601 Greensboro Avenue, Suite 100A, Tuscaloosa, Alabama • 205-722-2649

Contact Information
Point of Contact: Laura Beth Agee
Phone Number: (205) 722-2649
Code Adoption and Approval Dates
Date of Code Adoption: January 1, 2025
Date of Approval: February 6, 2025
Most Recent Update: February 6, 2025

Introduction
Swag, LLC is committed to conducting business ethically, responsibly, and sustainably. We
expect our suppliers, partners, and stakeholders to uphold the highest standards of integrity
and respect for human rights, labor laws, and environmental protection. Our supply chain
should reflect our core values of fairness, transparency, and social responsibility. This Code of
Conduct outlines the ethical and legal principles that all suppliers must adhere to in order to
maintain a partnership with Swag, LLC.

Code Elements

1. Forced Labor
Suppliers must not engage in or support any form of forced labor, including involuntary,
bonded, indentured, or prison labor. All work must be voluntary, and workers must have the
freedom to leave employment upon reasonable notice.

2. Employment Relationship
Suppliers must provide all workers with clear and understandable information about their
employment conditions, including wages, benefits, and working hours, in compliance with local
and international labor laws.

3. Nondiscrimination
Suppliers shall not discriminate against workers based on race, color, gender, age, religion,
nationality, disability, sexual orientation, or any other legally protected characteristic in hiring,
compensation, promotions, or any other employment practices.

4. Harassment or Abuse
Suppliers must ensure a workplace free from harassment, abuse, and any form of
mistreatment. Physical punishment, threats, verbal abuse, or any form of coercion is strictly
prohibited.

5. Child Labor
Suppliers must not engage in or benefit from the use of child labor. The minimum age for
employment must be in accordance with local laws and international labor standards, ensuring
that young workers are not subjected to hazardous work.

6. Health, Safety, and Environment
Suppliers must provide a safe and healthy work environment, ensuring compliance with
occupational health and safety regulations. Adequate measures must be in place to prevent
accidents, injuries, and exposure to hazardous substances. Suppliers must also take responsible
steps to minimize their environmental impact by reducing waste, emissions, and resource
consumption.

7. Hours of Work
Suppliers must comply with all applicable labor laws regarding working hours, including
overtime regulations. Workers shall not be required to work excessive hours and must receive
adequate rest periods.

8. Compensation
Suppliers must ensure that workers receive fair wages that meet or exceed the minimum legal
standard. Compensation should be paid in a timely manner, and all legally mandated benefits
must be provided.

Establishing an Internal Supply Chain Code of Conduct

Swag, LLC will implement the Supply Chain Code of Conduct internally to ensure alignment
across all operations. This includes integrating the code into procurement strategies,
onboarding processes, and compliance measures.

Reviewing and Approving the Code
The President of Swag, LLC will review and approve the Supply Chain Code of Conduct annually.
The approved code will be published on company letterhead and distributed to relevant
stakeholders.

Publishing the Code
To demonstrate our social responsibility commitments, Swag, LLC will publish the approved
Supply Chain Code of Conduct on our company website, ensuring transparency and
accessibility.

Training Staff
All staff will be educated on the Supply Chain Code of Conduct, its importance, and its impact
on our operations. This training will ensure employees understand their roles in upholding
ethical sourcing and labor practices.

Standard Operating Procedure for Supplier Engagement
For staff responsible for initiating new factory, intermediary, or supplier relationships or placing
orders, the following standard operating procedure applies:
• Prioritizing Ethical Suppliers: Train colleagues to prioritize suppliers that have engaged
in all the steps outlined in the Code of Conduct.
• Discussing Expectations: Equip colleagues with the tools to discuss Code expectations
with potential or new supply chain partners.
• Explaining Code Efforts to Customers: Support colleagues in explaining compliance
efforts and any timing implications to customers.

Regular Review and Communication
Swag, LLC will schedule regular reviews of the Code of Conduct to ensure it remains effective
and relevant. Any changes to the Code will be communicated via our website and incorporated
into staff training sessions.

Assessing Code Implementation and Addressing Violations
Swag, LLC will assess the implementation of the Supply Chain Code of Conduct at supplier
facilities through audits and evaluations. In the event of violations, we will partner with
suppliers to implement corrective actions. Additionally, sustained support from management
will ensure continued investment of time and resources into evaluation, remediation, and
improvement initiatives.

Supply Chain Code of Conduct with Supply Chain Partners

Obtaining Verification from Suppliers
To ensure compliance with our Code of Conduct, Swag, LLC will obtain verification from
suppliers to confirm adherence to ethical and legal standards. Verification strategies include:
• Requesting suppliers to sign a “verification of code compliance” statement.
• Asking suppliers to check and sign each code element to confirm understanding and
accountability.
• If a supplier has an existing code, ensuring it meets or exceeds Swag, LLC’s code
requirements.

Ensuring Awareness of Code Expectations
Potential new suppliers must be made aware of Swag, LLC’s code expectations before
establishing a partnership. Strategies include:
• Checking if suppliers have an FLA-aligned code of conduct published on their website.
• Sharing Swag, LLC’s code and ensuring that agreement to uphold the code is a
prerequisite for partnership.

Engaging in Ongoing Due Diligence
Swag, LLC will conduct ongoing due diligence to assess how suppliers communicate and uphold
our Code of Conduct within their own supply chains. Methods include:
Asking suppliers how they ensure compliance within their manufacturing facilities.
Engaging with supplier representatives during product knowledge or sales sessions to verify
adherence.

Including the Code in Business Agreements
To reinforce our commitment to ethical sourcing, Swag, LLC will include the Supply Chain Code
of Conduct in all business agreements, contracts, and purchase orders with suppliers.

Prioritizing Suppliers with Strong Compliance Systems

Swag, LLC will prioritize suppliers that demonstrate robust systems for upholding our Code of
Conduct. Strategies include:
• Tracking each supplier’s implementation of our code and maintaining a list of preferred
suppliers with high transparency and compliance standards.
• Utilizing industry databases such as Sage or ESP to record compliance status.
• Training sales representatives to prioritize purchases from preferred/strategic suppliers.
• Where possible, sourcing from the supply chains of FLA Accredited Member Companies
that adhere to FLA-aligned codes of conduct.