Kellwood Policy on Business Conduct

It is the desire of Kellwood Company, its Subsidiaries and Divisions, to not only be a good citizen of the United States, but also to conduct business in an ethical and moral manner in all of the countries of the world in which we have the privilege to work.

As the scope and breadth of Kellwood's sourcing and customer base expands to include more diverse cultures, we must insure that the business people and compa nies that we associate with have the same values that we expect from our own employees. To achieve this end Kellwood subscribes, and we endeavor to have our business partners subscribe, to the following principles in conducting business.

Ethical Standards: We endeavor to respect the ethical and moral standards and beliefs of all peoples and cultures that we deal with. We in turn expect our business partners to respect our rules and procedures.

Legal Requirements: We expect our employees and business partners to abide with the laws of the countries in which we conduct business. We also expect that international law related to the conduct of business between nations be followed at all times.

Health and Safety: We strive to have a safe and healthy working environment in all the facilities that Kellwood owns and operates. We also expect that any business partners that we provide work to will endeavor to provide a safe /healthy environment for the employees in the workplace, but also in the living facilities provided to the workers should this be necessary.

Environmental Safekeeping: We understand that the environment that we live in is ours to maintain and protect. We subscribe to manufacturing prac tices that insure the safekeeping of our natural resources and ecological sur roundings and expect our business partners to also adhere to these prin ciples.

Wages and Benefits: The wage and benefit structure of our suppliers must comply with the applicable laws of the Country or State.

Working Hours: We expect our suppliers to operate based on prevailing local work hours. Any time worked over the norm for the area should be compen sated at the overtime rate as prescribed by the local labor laws. We encour age our contractors and suppliers to allow workers a reasonable amount of time off from their duties for rest and being with their families.

Child Labor: The use of child labor is not permissible. For a definition of "child", we will look first to the national laws of the country in which busi ness is being conducted. If, however, the laws of that country do not provide such a definition or if the definition includes individuals below the age of 14, we will define "child", for purposes of determining use of illegal child labor, as any one who is:

(a) less than 14 years of age; or
(b) younger than the compulsory age to be in school in the coun try in which business is being conducted, if that age is higher than 14.

Prison/Forced Labor: We will not knowingly utilize or purchase materials and/or products manufactured by prison or forced labor.

Discrimination: We recognize and are aware that cultural differences will exist between various peoples. However, we do believe that people should be employed based on their ability to perform a needed function not on the basis of personal beliefs or characteristics.

Disciplinary Practices: We will not condone any type of corporal, mental or physical punishment by a supplier or an employee.

October 1992
Revised July 1996