Oxford Industries, Inc. Contractor Sourcing Policy

United States Department of Labour

General Policy: It is the firm policy of Oxford Industries, Inc. and its subsidiaries to do business only with contractors who adhere to the laws of their host countries. It is the responsibility of the Oxford contract manager or employee who hires the contractor (1) to insure that each contractor understands and agrees to abide by Oxford's policy in this regard, (2) to take reasonable steps to ascertain that the contractor is in fact in compliance with Oxford's policy, and (3) to document the steps taken to comply with this policy.

Contractors: This policy covers all manufacturing contractors, including, but not limited to, cutting, sewing, printing, embroidery, finishing, dyeing and laundry con tractors. Also covered are manufacturers who sell packages, i.e. completed garments whose price includes fabric and trim.

Domestic and Foreign Policies: Oxford has two versions of its Sourcing Policy, one for the United States and another for the rest of the world. The two versions are attached. The Sourcing Policy (United States) specifically requires adherence to the Fair Labor Standards Act, and federal, state and local child labor and fair employment laws. It also prohibits a contractor from hiring a worker who cannot legally work in the United States. The Sourcing Policy (Worldwide) prohibits the use of prison labor and addresses the issues of contractor-provided housing and transshipping.

Implementation: It is the responsibility of the contract manager or Oxford employee who hires the contractor to:

  1. Explain Oxford's Sourcing Policy to the contractor's officers and/or manag ers.
  1. Give a copy of the Sourcing Policy to the contractor.
  1. Obtain a copy of the Contractor's Acknowledgement and Agreement (copy attached) that has been signed by an officer of the contractor and maintain this document in a safe and readily accessible place. The relevant version of the Sourcing Policy should be attached.
  1. Periodically remind the contractor of its commitment to adhere to the Sourc ing Policy.
  1. Take reasonable steps to ascertain the contractor's compliance with the Sourc ing Policy. Depending on the location of facility these steps may include reviewing the age documentation of workers who appear to be underage, inspecting contractor-provided housing, speaking directly with workers about wage payments and other working conditions and randomly checking per sonnel files.
  1. Report all violations and suspicions of violations to the appropriate Oxford manager.

Questions: Any questions about the Sourcing Policy and its implementation should be directed to Oxford's Legal Department.

OXFORD INDUSTRIES, INC.
SOURCING POLICY
(WORLDWIDE)

Oxford Industries, Inc. expects each of its manufacturing contractors to treat its em ployees in a fair and equitable manner. To that end Oxford will only employ those contractors who abide by the following standards:

Children and Prisoners: No contractor shall use prison labor or the labor of children below the minimum working age in the host country.

Wages and Benefits: Each contractor must pay its employees at least the minimum required wages and benefits mandated by the laws of the host country. Wages and benefits must be calculated and paid according to the laws of the host country.

Health and Safety: Each contractor must provide a safe and healthy work place to its workers.

Employee Living Conditions: If a contractor provides housing or suste nance to its employees, these shall be at least to the normal standards of the host country.

Subcontracting: No contractor may subcontract work without the express written permission of Oxford and then such subcontracting shall only be permitted to companies that abide by this Sourcing Policy.

Transshipping: All work shall be performed in the country of origin which has been identified by the contractor.

Violation of this Sourcing Policy may lead to the immediate cancellation of produc tion contracts with the contractor.

ACKNOWLEDGEMENT AND AGREEMENT

____________("Contractor"), with a facility address of_________________, hereby acknowledges that it has received and understands the Oxford Industries, Inc. Sourc ing Policy, a copy of which is attached to this Acknowledgement and Agreement, and in consideration of being hired to manufacture certain products for Oxford Industries, Inc., Contractor agrees to comply in all respects with the requirements of the Oxford Industries, Inc. Sourcing Policy.

(Name of Contractor)
(Signature)
(Print Name)
(Title)
(Date)