Follett Higher Education Group

I. Introduction: Follett Higher Education Group is committed to conducting its business affairs in a socially responsible manner. Follett expects the same of its business partners. Follett, therefore will sell only those products and goods tare are manufactured in a manner consistent with this Vendor Labor Practice Code. When appropriate, Follett will seek to join educational institutions, vendors, agent, businesses and human rights, labor, and governmental organizations in demonstrating its commitment to socially responsible business practices by engaging in a periodic review of this Code of Conduct to ensure that it is consistent with evolving business and social standards.

II. Application: This Code of Conduct shall apply to all vendors providing products and services to Follett. Throughout this Code, the term, "Vendor" shall include all persons or entities who have entered into written agreements with Follett, as well as their respective contractors, subcontractors, vendors, manufacturers, sublicenses, and any related entities throughout the world which produces or sell products or materials incorporated in products sold to and through Follett.

III. Workplace Standards and Practices: Specifically, vendors must operate workplaces and contract with employers whose workplace adhere to the following minimum standards and practices.

A. Legal Compliance
Vendors must comply with all applicable legal requirements in conducting business related to or involving the production or sale of products or materials to Follett.

B. Environmental Compliance
Vendors must share Follett's commitment to the protection and preservation of the global environment and the world's finite resources and conduct business accordingly.

C. Ethical Principles
Vendors must be committed in the conduct of their business to a set of ethical standards that are not incompatible with those of Follett. These include but are no means limited to honesty, integrity, trustworthiness, and respect for the unique intrinsic value of each human being.

D. Employment Standards
Vendors will only do business with manufacturers whose workers are in all cases voluntarily present at work, not a risk of physical harm, fairly compensated, and not exploited in any way. In addition, the following specific guidelines must be followed:

1. Wages and Benefits: Manufacturers must provide wages and benefits that comply with all applicable laws and regulations and match or exceed the prevailing local manufacturing industry practices.

2. Working Hours: Manufacturers shall not require workers to work more that the lessor 48 regular working hours per week, or the limit on regular working hours under applicable local law, and shall provide workers with at least one day off in every 7-day period. With respect to appropriately compensated overtime, manufacturers shall not schedule overtime on a regularly scheduled basis in excess of the lesser of the standard work week plus 12 hours of overtime or 48 standard hours plus 12 hours of overtime, unless extraordinary business circumstances exist.

3. Child Labor: The use of child labor is not permissible and will not be tolerated. Manufacturers must meet all applicable local laws regarding the minimum age of workers. Workers can be no less than fourteen years of age and not younger that the compulsory age to be in school for the country where the work is to be performed.

4. Forced Labor: Manufacturers shall not use involuntary labor, including forced, prison, bonded or indentured labor.

5. Health and Safety: Manufacturers must comply with applicable local law in providing workers with a safe and healthy environment. If residential facilities are provided to workers, they must be safe and healthy facilities.

6. Non-Discrimination: While Follett recognizes and respects cultural differences, all workers must be employed on the basis of their ability to do the job, rather than on any personal characteristic. Manufacturers shall not discriminate in hiring, salary, benefits, performance evaluation, discipline, promotion, retirement or dismissal.

7. Harassment or Abuse: Manufacturers shall treat workers with dignity and respect. No worker shall be subject to any physical, sexual, physchological or verbal harassment or abuse.

8. Disciplinary Practices: Manufacturers will not use or tolerate corporal punishment or any other form of psychological or physical coercion.

9. Freedom of Association: Manufacturers shall recognize and respect the legal right of workers of freedom of association and collective bargaining. Employees should not be the subjects of intimidation or harassment in the peaceful exercise of their right to join or to refrain from joining any organization.

10. Human Rights: Products and materials shall not be manufactured or produced in any country where the human rights environment, as determined by Follett, in its sole discretion, would prevent the conduct of business activities in a manner that is consistent with the Code of Conduct.

11. Legal System: Products and materials shall not be manufactured or produced in any country where the local legal system would prevent Follett, in its sole discretion, from adequately protecting its name, trademarks, images, or other interests or from implementing any provision of the Code.

12. Political, Economic and Social Environment: Products and materials shall not be manufactured or produced in any country where the political, social or economic environment would threaten Follet's reputation and/or commercial or other interests.

IV. Verification: It shall be the responsibility of each vendor to ensure its compliance with this Code and to verify that it's business partners, subcontractors, and others involved in the production of manufacture of products or materials for Follett are in compliance with this Code. Each vendor shall maintain on file such documentation as may be needed to demonstrate its compliance with this Code and shall make the documentation available for inspection upon request by Follett or Follett's designee.

A. Monitoring Compliance
Follett recognizes that an effective and responsible monitoring mechanism is crucial to the successful implementation of this Code of Conduct. In order to provide a meaningful monitoring procedure , therefore, Follett has designated an independent third party external monitor whose obligation it is to investigate compliance with this Code. Each vendor shall provide Follett's designated external monitor with physical access to all facilities where products are made, in whole or in part, whether by the vendor or by third parties with whom the vendor or its agent or representative contracts, in order to monitor and verify compliance with this Code of Conduct. Follett's designated external monitor shall be authorized to perform announced and unannounced visits to facilities for the purpose of monitoring compliance with this Code.

Upon request, and on January 1 of each year, every vendor shall promptly provide Follett's external monitor with the following information concerning each such facility where products to be sold by Follett are made: (1) the name, address, telephone number and facsimile number of the facility; (2) the name, address, telephone number and facsimile number of the owner(s) of the facility; (3) the name and job title of the contact person at the facility; (4) a detailed description of the type and quantity of all products made, assembled, or processed, in whole or in part, at the facility; (5) a summary description of the vendor's relationship to the owners and/or operators of the facility (e.g. company owned, contractual, etc.); and (6) any other information Follett's external monitor deems necessary to effectively monitor and verify compliance with this Code.

It shall be the vendor's responsibility under this agreement to promptly notify Follett's external monitor whenever it creates or ends relationships with new entities or facilities for the manufacture or assembly of products, in whole or in part to be sold to Follett. If the vendor fails to do so, and Follett incurs any expense as the result of the vendor's failure to notify Follett's external monitor pursuant to this paragraph, then the vendor shall reimburse Follett for all such expenses.

B. Confidentiality
Any information requested or provided in section A above will be treated as confidential by Follett and Follett's external monitor. Said information will not be disclosed to other third parties unless Follett is required to do so by law or compelled to do so legal process. Further, said information will be used solely to monitor, ensure and improve compliance with this Code of Conduct.

V. Vendor Remediation: All products, in whole or in part, sold to Follett must be manufactured in compliance with this Code of Conduct. If Follett in its sole discretion, determines that a product has been made in violation of this Code, then Follett will consult with the vendor to determine the appropriate measures to be taken. The remedy will include the vendor taking steps necessary to correct such violations. If consultation and agreed upon measures fail to adequately resolve the violations within a specified time period, Follett shall remove non-complying product from Follett's inventory, and return it to the vendor at the vendor's sole expense, for full credit.

VI. Employee Compliance: Any Follett Higher Education Group employee who knowingly purchases products to be sold by Follett that are in violation of this Code may be subjected to discipline up to and including discharge.

VII. Communication and Notification: Vendors must ensure that the management staff of each manufacturing facility has read and understood the requirements of this Code, and that the management staff effectively communicates the terms of this Code to the workers in the facility.


Last Updated September 2007