Supplier Code of Conduct

Outdoor Gear, Inc. is dedicated to ensuring that working conditions in our supply chain are safe, that workers are treated with respect and dignity, that actions are fair and ethical, and that environmentally responsible practices are employed. Therefore, it is essential that Outdoor Gear, Inc. suppliers (Suppliers’) commit to operate in full compliance with the laws, rules, and regulations of the countries in which they operate in all their activities. Outdoor Gear, Inc. (‘OGI’) requires that Suppliers implement the Outdoor Gear, Inc. Social Responsibility Code of Conduct (‘Code’) as outlined in this document. OGI may visit (or have external monitors visit) Supplier facilities, with or without notice, to assess compliance with this Code. When requested, Suppliers will provide OGI with the necessary documentation to complete the assessment. Violations of this Code may lead to Supplier disqualification.

Fundamental to adopting our Social Responsibility Code of Conduct is the understanding that a business, in all its activities, must operate in full compliance with the laws, rules, and regulations of the countries in which it operates. This Code encourages suppliers to exceed mere legal compliance, drawing upon internationally recognized standards (e.g., SA8000, Ethical Trading Initiative Base Code) to advance social responsibility. These requirements apply to every factory, subcontractor, licensee, agent, or affiliate that supplies materials or manufacturers and finishes products for Outdoor Gear, Inc. By working together, we can ensure that the products made for Outdoor Gear, Inc. are not only of the highest quality but also produced under working conditions that fully comply with applicable laws, rules, and regulations.

Labor and Human Rights

Suppliers must respect the human rights of workers, treating them with dignity and respect as recognized by the international community.

Antidiscrimination

Suppliers shall not discriminate against any worker based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, marital status, or any other condition that could lead to discrimination in hiring and employment practices. This includes applications for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline, and termination. Suppliers shall not require a pregnancy test or discriminate against pregnant workers, except as required by applicable laws or regulations or when necessary for workplace

Antidiscrimination(cont.)

safety. Furthermore, suppliers shall not require workers or potential employees to undergo medical tests that could be used discriminatorily, except where mandated by applicable law or regulation or when necessary for workplace safety.

Fair Treatment

Suppliers shall commit to maintaining a workplace free from harassment and abuse. Suppliers must not threaten workers or subject them to harsh or inhumane treatment, including but not limited to sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, verbal abuse, or other forms of intimidation. Factory managers and supervisors must never threaten or practice any form of physical discipline or harmful physical contact, regardless of how slight. Management will discipline anyone-including managers or fellow workers-who engages in physical, sexual, psychological, or verbal harassment or abuse; this may include combinations of counseling, warnings, demotions, and termination. Factories must establish procedures for disciplining and terminating workers that are applied consistently throughout the facility. Disciplinary measures must be documented in the worker’s file, and a copy of such warnings should be given to the worker. Factories must maintain functional and effective processes that allow workers to voice their concerns. These processes must be accessible and understandable to workers and should include a mechanism to ensure that grievances are addressed. Suppliers shall prohibit all forms of harassment and unlawful discrimination in the workplace.

Freedom of Association

Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Suppliers are to respect the rights of workers to associate freely and to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment. Workers’ rights to join labor unions of their own choosing and to bargain collectively, seek representation and/or join worker’s councils in accordance with local laws should be acknowledged. Factories must not impose any punitive actions against workers in supporting union such as threatening, fining, suspending or firing workers exercising those rights. Any action that suppresses freedom of association is prohibited and maybe an act deemed illegal in some countries’ labor codes.

Prevention of Involuntary Labor

Suppliers must not use any form of forced, slave, bonded, indentured, or prison labor. All work must be voluntary, and workers should be free to leave their job or terminate their employment with reasonable notice. Neither the Supplier nor any entity providing labor to the Supplier shall engage in or support trafficking in human beings. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment. Suppliers must ensure that third-party agencies providing workers to them comply with the provisions of the Code and the laws of both the sending and receiving countries, whichever offers greater protection for workers. Suppliers must ensure that contracts for both direct and contract workers clearly convey the conditions of employment in a language understood by the recipient’s worker.

Prevention of Underage Labor

Child labor is strictly prohibited. Suppliers must not employ children. The minimum age for employment or work is 15 years, the minimum legal working age of the country, or the age required to complete compulsory education in that country, whichever is higher. The factory must implement effective age verification procedures to ensure that every personnel file contains copies of the identified documents (such as birth certificates, national ID cards, or school certificates) submitted by applicants. Juvenileworkers (under the age of 18) are prohibited from working at night or engaging in “hazardous work, " as defined by the ILO. This Code supports participation in legitimate workplace apprenticeship programs that comply with all laws and regulations.

Juvenile Worker Protections

Suppliers may employ juveniles who are older than the applicable legal minimum age for employment but younger than 18 years, as long as they do not perform work that could jeopardize their health, safety, or morals. Therefore, in cases where these young workers are subject to compulsory education laws, they may only work outside of school hours, and in no case shall they work more than 8 hours in a single day. These policies and procedures must conform to the provisions of the relevant ILO standards.

Regular Employment is Provided

To the fullest extent possible, work performed must be based on a recognized employment relationship established through national law and practice. Obligations to employees under labor or social security laws and regulations arising from the regular employment relationship shall not be evaded through the use of labor-only contracting, subcontracting, or home working arrangements, nor through apprenticeship schemes that lack a genuine intent to impart skills or provide regular employment. Additionally, such obligations shall not be avoided through the excessive use of fixed-term employment contracts.

Working Hours

Suppliers shall maintain reasonable employee work hours, and under no circumstances shall workweeks exceed the maximum permitted by applicable laws and regulations. Additionally, if collective agreements are in place, working hours must adhere to those agreements. Workers shall receive at least one day off after every six consecutive days of work. Suppliers must comply with all applicable laws and regulations regarding working hours and days of rest. Where a country’s legal code specifies the regular workday, workweek, rest days, and/or holidays, factory schedules must align with the law. Time records for all workers must be available for review. Employees are required to keep their own time records (i.e., punch in and out themselves). Factories must accurately and completely record all employee working hours. All overtime hours must be consensual and compensated at a premium rate.

Student Worker Protections

Suppliers shall ensure effective management of student workers by properly maintaining student records, conducting thorough due diligence of educational partners, and safeguarding students’ rights in accordance with applicable laws and regulations. They shall provide appropriate support and training to all student workers.

Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those related to minimum wage, overtime hours, and legally mandated benefits. Deductions from wages as a disciplinary measure shall not be permitted, nor shall any deductions not provided for by national law occur without the expressed consent of the worker concerned. All disciplinary measures shall be documented. Suppliers shall offer vacation time, leave periods, and holidays in line with applicable laws and regulations. All overtime work shall be voluntary, except in circumstances where it is necessary to meet short-term business demand AND the company is part of a freely negotiated collective bargaining agreement with worker organizations representing a significant portion of the workforce. Overtime shall be reimbursed at a premium rate as defined by national law. In countries where a premium rate for overtime is not mandated by law or a collective bargaining agreement, personnel shall be compensated at a premium rate or in accordance with prevailing industry standards. Suppliers shall pay workers promptly and clearly communicate the basis for their wages. Payroll records for all workers must be accessible for review. All workers shall receive written and comprehensible information about their employment conditions regarding wages before they begin work and details about their pay for the current pay period each time they are compensated.

Health and Safety

Outdoor Gear, Inc. recognizes that integrating sound health and safety management practices into all aspects of business is essential for maintaining high morale and producing quality products. Suppliers must commit to creating safe working conditions and a healthy work environment for all their workers. Workers have the right to refuse unsafe work and to report unhealthy working conditions.

Occupational Injury Prevention

Suppliers must eliminate physical hazards whenever possible. If physical hazards cannot be eliminated, Suppliers must implement suitable engineering controls such as guards, interlocks, and barriers. If suitable engineering controls are not feasible, Suppliers must establish appropriate administrative measures, like safe work procedures. In all instances, Suppliers must provide workers with the necessary personal protective equipment. Workers will not face discipline for voicing safety concerns and have the right to refuse unsafe working conditions without fear of retaliation until management properly addresses their concerns.

Prevention of Chemical Exposure

Suppliers shall identify, evaluate, and control worker exposure to hazardous chemical, biological, and physical agents. They must eliminate chemical hazards whenever possible. If chemical hazards cannot be eliminated, suppliers shall provide appropriate engineering controls, such as closed systems and ventilation. When appropriate engineering controls are not feasible, suppliers shall establish appropriate administrative controls, such as safe work procedures. In all cases, suppliers shall provide workers with suitable personal protective equipment. Factories must comply with legal requirements to inform government or local agencies (such as fire departments) regarding chemicals used or stored on-site. Suppliers must demonstrate a consistent, effective, and legally compliant approach to chemical management. The program must clearly identify and mitigate chemical risks to workers, the environment, and consumers by facilitating the procurement, proper handling, storage, use, and disposal of chemicals.

Emergency Prevention, Preparedness, and Response

A senior factory manager must be assigned the responsibility of ensuring that the factory has procedures in place to prepare for and respond to emergency situations. Suppliers should anticipate, identify, and assess emergency situations and events (such as fires, earthquakes, hurricanes, and chemical spills) and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, worker notification, and evacuation procedures, worker training and drills, appropriate first-aid supplies, suitable fire detection and suppression equipment, adequate exit facilities, and recovery plans. Evacuation plans must be posted in each work area. Factories must have assigned locations that can shelter the entire workforce in case of a severe weather event. Emergency evacuation drills must be conducted regularly so that workers are familiar with the drill procedures and consider them routine. Workers on all shifts should be trained to use fire extinguishers. Factories should have rules and procedures to ensure that aisles and exits are kept clear, are properly and clearly marked, and allow all workers to exit quickly and safely leave the factory in an emergency. Fire alarms should be tested regularly and maintained in proper working order.

Building Integrity

Factories must possess a valid building certificate of occupancy. They must also provide the legal classification of the site concerning earthquake zones, flood areas, soil composition and saturation, groundwater levels, heavy rainfall, flooding, snow load, and landslide risk. The buildings must comply with the basic Tier 1 acceptance criteria set by ASCE 41-13 or a comparable national seismic standard for evaluating existing structures. The factory's structure must not exceed the maximum expected loads specified in the building’s certificate of occupancy. Factories must be well-maintained and free from signs of vandalism, with walls, doors, and windows devoid of cracks, broken panes, or other damage.

Aisles and Exits

Emergency exits must remain unlocked during working hours to allow workers to exit during emergencies. Factories must have enough exits to safely accommodate the number of workers, as well as the height and type of building or structure. Exit doors must not require special operation. Exit doors and exit routes must be clearly marked so that they are visible to factory workers throughout the facility. An assembly area must be designated outside the facility for accounting for evacuated workers in an emergency.

Electrical Safety

Factories must keep wiring and electrical systems in a safe condition. All electrical wires must be properly insulated, and electrical junction boxes should be covered. All electrical connectors must remain in good condition. All electrical equipment must be adequately grounded.

Powered Industrial Trucks

Only authorized workers who have been properly trained and evaluated may operate or maintain powered industrial trucks. All workers using, adjusting, or maintaining powered industrial trucks must be trained to perform these jobs safely. Additionally, all powered industrial trucks must have a functioning and audible backup alarm while reversing.

Machine Safety

Factories must routinely inspect equipment to ensure it functions properly and that guards are appropriately in place. Workers must receive machine safety training for the machines they operate. Factories should maintain written records of equipment and the services performed on it. It is highly recommended that all sewing machine needles have guards to prevent injuries to operators from broken needles. Sewing needles that are permanently protected by fabric folders or guides do not require additional guards. Operators should wear safety glasses when using sewing equipment, unless the machines are equipped with eye shields. Moving machine parts and drive belts should be guarded at the point of operation.

Occupational Safety Procedures and Systems

Suppliers must establish procedures and systems to manage, track, and report occupational injuries and illnesses. These procedures and systems should encourage worker reporting, classify and record injury and illness cases, investigate incidents, implement corrective actions to eliminate their causes, provide necessary medical treatment, and facilitate workers’ return to work.

Ergonomics

Suppliers must identify, evaluate, and manage workers’ exposure to physically demanding tasks, such as manual material handling, heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks.

Dormitory and Dining

Suppliers must provide workers with accessible and clean toilet facilities, access to potable water, and, where applicable, sanitary food preparation and storage areas. Worker dormitories provided by the Supplier or a third-party agency must be clean, safe, and adequate emergency egress, proper heating and ventilation, reasonable personal space, and appropriate entry and exit privileges. Dormitories must comply with all housing laws, occupancy requirements, and health and safety regulations

Health and Safety Communication

To foster a safe work environment, suppliers shall provide workers with appropriate workplace health and safety information and training, including written health and safety information and warnings, in the primary language of the workers. Suppliers shall post, in the primary language of their workers, Material Safety Data Sheets for any hazardous or toxic substances used in the workplace and properly train workers who will come into contact with such substances.

Worker Health and Safety Committees

Suppliers are encouraged to establish and support worker health and safety committees to improve ongoing health and safety education and promote worker input on health and safety issues in the workplace. A written record of the Safety Committee meetings must be established by the committee leaders (management representative and factory worker) and maintained on file for at least five (5) years. Heads of the Safety Committee must have the authority to consult with external experts if necessary. Safety Committee members should be trained to: 1) investigate accidents and other health and safety incidents at the factory; 2) conduct inspections and identify hazards; 3) assess and analyze health and safety trends; and 4) utilize health and safety resources within the factory or community. A Safety Committee member must participate in all accident and incident investigations. Safety Committees should conduct thorough inspections of the factory at least every three months and document the results.

Permits

Permits must be available for review. Factories must possess all current permits required by law, including business and operating permits, fire safety and electrical certificates, permits for equipment such as boilers, generators, elevators, fuel and chemical storage tanks, as well as building, emissions, and waste disposal permits.

Training

Workers shall receive regular and documented health and safety training, and this training shall be repeated for new or reassigned workers. Insofar as the Supplier transports goods for Outdoor Gear, Inc. into the United States, the Supplier must comply with the C-TPAT (Customs-Trade Partnership Against Terrorism) security procedures provided on the U.S. Customs Website atwww.cbp.gov (or any other website established for this purpose by the U.S. Government).

Ethics

Outdoor Gear, Inc. expects the highest standards of ethical conduct in all of our endeavors. Supplier shall always be ethical in every aspect of their business, including relationships, practices, sourcing, and operations.

Business Integrity

Corruption, extortion, embezzlement, and bribery in any form are strictly prohibited. Suppliers must not violate the Foreign Corrupt Practices Act (FCPA), any international anti-corruption conventions, or applicable anti-corruption laws and regulations of the countries in which they operate. They must not engage in corruption, extortion, or embezzlement in any form. Suppliers must not offer or accept bribes or any other means to gain an undue or improper advantage. Suppliers are required to uphold fair business standards in advertising, sales, and competition.

Disclosure of Information

Suppliers must accurately record and disclose information regarding their business activities, structure, financial situation, labor, health and safety, and environmental practices and performance in accordance with applicable laws, regulations, and prevailing industry practices. Factories must maintain only one complete and accurate set of working hours and payroll documents that reflect true work conditions. Factories must never present or require workers to sign blank papers or resignation letters.

Whistleblower Protection and Anonymous Complaints

Suppliers must establish programs to protect the confidentiality of suppliers and worker whistleblowers, and to prohibit retaliation against workers who participate in these programs in good faith or refuse an order that violates the OGI Supplier Code of Conduct. Suppliers are required to provide an anonymous complaint mechanism that allows workers to report workplace grievances in compliance with local laws and regulations, and they must prohibit retaliation.

Community Engagement

Suppliers are encouraged to engage with the community to help promote social and economic development and to contribute to the sustainability of the communities in which they operate.

Protection of Intellectual Property

Suppliers must respect intellectual property rights, safeguard customer information, and ensure that the transfer of technology and know-how protects these rights.

Animal Fur and Exotic Leather

Suppliers are prohibited from using animal fur and exotic leather in materials and products supplied to Outdoor Gear, Inc.

Environmental Impact

Suppliers must understand that environmental responsibility is essential for producing high-quality products. In manufacturing operations, it is crucial to minimize adverse effects on the environment and natural resources while ensuring the health and safety of the public.

Product Content Restrictions

Suppliers must comply with applicable laws and regulations concerning the prohibition or restriction of specific substances, including those related to labeling, recycling, and disposal.

Chemical and Hazardous Materials

Hazardous chemicals and other materials must be identified and managed to ensure their safe handling, movement, storage, recycling, reuse, or disposal in the environment.

Environmental Permits and Reporting

All necessary environmental permits and registrations must be obtained, maintained, and kept up to date, and their operational and reporting requirements must be followed.

Non-Hazardous Waste Management

Suppliers must adopt a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non-hazardous waste.

Hazardous Waste Management

Suppliers must properly segregate, manage, transport, and dispose of all solid and hazardous waste in accordance with local laws and regulations. They must obtain all necessary permits and ensure that subcontractors handling solid and hazardous waste are properly qualified and licensed. Suppliers should also measure waste generation and continuously strive to minimize it.

Wastewater Management

The supplier shall implement a systematic approach to identify, control, and reduce wastewater produced by its operations. The supplier shall conduct routine monitoring of the performance of its wastewater treatment system.

Air Emissions Management

Supplier shall identify, manage, reduce, and responsibly control air emissions emanating from its operations that pose a hazard to the environment. Supplier shall conduct routine monitoring of the performance of its air emission control systems. Supplier will strive to minimize emissions through improved efficiency and use of renewable energy sources.

Management Commitment

Suppliers must establish a management system designed to ensure compliance with this Code and applicable laws and regulations, identify and mitigate related operational risks, and facilitate continuous improvements. The management commitment should include the following elements: Top management shall define in writing, in the workers’ own language, the company’s policy for social accountability and labor conditions and display this policy and the SA8000 standard in a prominent and easily viewable place on the company’s premises. This policy shall clearly include the following commitments:

•To comply with all requirements of this code/standard.

•To comply with national and other applicable laws and requirements that apply to this company subscribes.

•To regularly review its policy for ongoing improvement, considering changes in legislation and its own code of conduct requirements.

•To ensure that its policy is effectively documented, implemented, maintained, communicated, and presented in a comprehensible format for all personnel–whether directly employed, contracted, or otherwise representing the organization company.

The company shall appoint a senior management representative who, regardless of other responsibilities, shall ensure that the requirements of this standard are met.

Legal and Customer Requirements

Identification, monitoring, and understanding of applicable laws, regulations, and customer requirements. Suppliers must have processes in place to identify, comprehend, and implement relevant laws, regulations, and the requirements of this Code. Suppliers shall maintain documents and records to ensure regulatory compliance compliance.

•Factories must comply with any legal judgments against them them.

•Factories must comply with Rules of Origin laws and regulations.

•Factories need to understand Country of Origin requirements to ensure compliance.

Training and Communication

Programs to train managers and workers in implementing Supplier’s workplace policies and procedures. A process for communicating clear, accurate information about Supplier’s workplace practices and expectations to workers, suppliers, and customers.

Risk Assessment and Risk Management

Process for identifying health and safety, business ethics, labor and human rights, and legal compliance risks associated with the Supplier’s operations. Determine the relative significance of each risk and implement appropriate procedural and physical controls to ensure legal and regulatory compliance and manage the identified risks.

Audits and Assessments

Regular self-evaluations to ensure compliance with legal and regulatory requirements as well as the OGI Supplier Code of Conduct.

Corrective Action Process

Procedure for prompt correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.

Control of Sub-Suppliers / Sub-Contractors

The supplier must keep accurate records of sub-suppliers and sub-contractors and secure written commitments that they will comply with all requirements of this Code, as well as all applicable labor, employment, business, and ethics laws and regulations