ETHICAL MANUFACTURING & PROCUREMENT POLICY

At the A.I. Group we represent some of the biggest brand names in the world and therefore we require that our manufacturing partners and suppliers (“Supplier”) adhere to certain standards.

At A.I. we believe in:

A standard of excellence in all we do

Conducting our business in a responsible and ethical manner

We respect the rights of individuals

We respect the environment

We expect our suppliers to share these beliefs, and as a supplier for the A.I.Group we require that the following standards as outlined in our Ethical Manufacturing & Procurement Guidelines are met.

The A.I. Groups' Ethical Manufacturing & Procurement Guidelines below were adopted by the Directors on January 8^th, 2008. Implementation of the Guidelines will be phased in over time, and will vary across Asia Incentives business units. For more information, please contact info@aussieincentives.com

The A.I. Groups Ethical Manufacturing & Procurement Guidelines (“Guidelines”) reflect the commitment of A.I. and its subsidiaries and affiliated companies (“A.I. Group or A.I.”) to conduct business according to standards of integrity and ethics. It is important that all of our Suppliers conduct business in compliance with local laws and regulations and industry standards. For the purposes of these Guidelines, “Supplier” is synonymous with terms that may include but are not limited to supplier, factory, licensee, site, facility, contractor and sub-contractor.

The International Labor Organization (ILO) Core Labor Conventions, as established by the tripartite United Nations affiliated agency, have served as the foundation upon which much of these Guidelines are based.

Employment

1. Non-Discrimination
A.I. expects that Supplier will not discriminate in recruitment, hiring, training and employment practices, including compensation, benefits, advancement, discipline, termination or retirement, on the basis of race, color, religion, age, national origin, sex (including pregnancy), sexual orientation, marital status, physical or mental disability or any other category protected by law that does not affect an individual’s ability to do the job.

2. Child Labor
A.I. expects that Supplier will not employ any person under the age of 15 (or 14 where local law allows) or younger than the age for completing compulsory education in the country of manufacture where such age is higher than 15. Workers under 18 years of age should not perform work likely to jeopardize the health or safety of young persons. All suppliers should also adhere to legitimate workplace apprenticeship programs and comply with all laws and regulations governing child labor and apprenticeship programs.

3. Involuntary Labor
A.I. expects that Supplier will not use any forced or involuntary labor, whether prison, bonded, indentured or otherwise. Supplier will not require employees to relinquish any personal identification, including but not limited to passports, identification cards or work permits, as a condition of employment.

4. Coercion and Harassment
A.I. expects that Supplier will treat each employee with dignity and respect, and will not use corporal punishment, threats of violence or other forms of physical, sexual, psychological or verbal harassment or abuse.

5. Association
A.I. expects that Supplier will allow freedom of association when allowed by local law, and in all cases respect the right of employees to communicate openly and directly with management and will not intimidate, harass or reprimand employees for doing so.

6. Working Hours and Compensation
A.I. expects that Supplier will comply with all wage and hour laws as mandated by applicable country law or industry standard. A.I. also expects that employees will not routinely work in excess of sixty hours per week and employees will be provided with a minimum of one rest day in every seven-day week.

7. Statutory Social Security and Welfare Benefits
A.I. expects that Supplier will contribute to all statutory social security and welfare funds to which employers and/or employees are required by applicable laws to contribute, including medical insurance, industrial injury insurance, pension, housing and unemployment funds, as well as contribute to these funds on behalf of all employees in accordance with all relevant laws and regulations.

8. Employment Records
A.I. expects that Supplier will retain one year of complete and accurate records and documentation, including employment contracts, residence and work permits (if applicable), proof of age documentation, maternity leave records, industrial injury reports, and work time and pay records, relating to employees in manufacturing and operations positions necessary to demonstrate compliance with these Guidelines other than information and records that applicable law requires Supplier to retain for a shorter period of time.

Health & Safety and Environment

9. Health and Safety
A.I. expects that Supplier will provide employees with a safe and healthy workplace in compliance with all applicable laws and regulations, ensuring at a minimum, occupational safety, machine guarding, emergency preparedness, industrial hygiene, reasonable access to potable water and sanitary facilities, fire safety, and adequate lighting and ventilation. Any Supplier that is a manufacturer will also ensure that the same standards of health and safety are applied in any housing or canteen facilities that it provides for employees.

10. Environment
A.I. expects that Supplier will comply with all applicable environmental laws and regulations and ensure that all required environmental permits and registrations are obtained, maintained and kept current and that operational and reporting requirements are followed.

Intellectual Property & Ethics

11. Copyright Protection
A.I. expects that Supplier will respect all intellectual property rights and will not copy or allow third party access to any A.I. content without authorization, including but not limited to any form of trade marks, logos or designs.

12. Business Ethics
A.I. expects Suppliers to implement effective ethics and compliance programs.

Implementation and Compliance

These Guidelines highlight A.I. Groups’ expectations of the manner in which its Suppliers will conduct themselves in their business relationships with A.I.. The A.I. Group recognizes that achieving the standards established in these Guidelines will be a dynamic rather than a static process and encourages Suppliers continually to improve their workplace conditions.

A.I. expects that its Suppliers will establish and maintain appropriate management systems, the scope of which is consistent with the content of these Guidelines, and actively review, monitor and modify their management processes and business operations to ensure that their operations align with the principles set forth in these Guidelines. A.I. expects that Supplier will work with its own suppliers and subcontractors to ensure that they also strive to meet the principles of these Guidelines or an equivalent set of principles.

It is entirely within A.I. Groups’ discretion whether to continue to use a Supplier, subject to contractual obligations. A.I. reserves the right to take such actions as it deems appropriate, in its discretion, to monitor and promote compliance with these Guidelines. The failure to consistently meet these standards may impact the future ability to do business with the A.I. Group.