Social Compliance Statement

Calibre International is committed to conducting all of our business activities with integrity, social responsibility and in compliance with all legal and ethical standards of each of the countries we conduct business in. Calibre International and its manufacturers shall comply with all applicable national, state, provincial and local laws and regulations, industry standards, UN Conventions, and any other requirements that pertain to product safety, employment practices and product manufacturing. Calibre International requires strict compliance with this commonly accepted Code of Conduct from all of our suppliers, manufacturers, subcontractors and other production facilities. Calibre believes that by insisting on compliance, it will allow us to offer safe products, produced in a safe environment, while complying with all applicable national, local and international laws and regulations. To do this, they must ensure compliance with the following:

Child Labor

Calibre International absolutely forbids the use of child labor as defined by ILO and United Nations Conventions or by the national law of the country where the work is being performed.

All employees must meet the country’s minimum age requirement to act as labor. All factories that conduct business with Calibre must maintain official records that verify the employee’s date of birth and date of employment. This documentation must be available for inspection at any time.

Forced Labor

Calibre International prohibits the use of prison or forced labor in the manufacturing of our products. This policy extends to all other third party suppliers or subcontractors that are involved in the manufacturing of Calibre’s products.

Wages, Hours and Benefits

Our manufacturers and their associated suppliers must comply with all laws regulating wages, working hours, overtime and employee benefits for the particular country in which they are located.

All workers must be paid at least the national minimum wage.

Prohibition of Discriminatory Practices

Workers will not experience discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on gender, age, religion, race, caste, social background, disability, ethnic and national origin, political affiliation, sexual orientation, or any other personal characteristics.

Health and Safety

The workplace must be a safe and healthy environment based on the recognized international standards, local laws and regulations.

The factory and all work areas must be well lighted and ventilated.

The workplace must have sufficient operational and inspected fire extinguishers, and people trained to operate them. The workplace must also have functioning fire alarms.

All work areas must have clearly marked exits. These exits must remain unlocked and accessible during all working hours. All doors, aisles, exits, stairwells and traffic areas are to be kept clear and accessible for easy evacuation.

All equipment must be maintained in good operating condition and up to code.

All factories must provide a well-stocked first-aid kit in each work area.

Environment Issues

All factories must abide by all local and national environmental laws.

The factory must have in place policies and procedures for waste management, handling and disposal of chemicals and other dangerous materials. All emissions and effluent treatments must meet or exceed minimum legal and regulatory requirements.

Calibre insists our vendors and their associated suppliers share our commitment to a clean and safe environment.

Calibre International reserves the right to either conduct its own inspections or have an appointed third party organization conduct inspections of Calibre’s supplier’s factories, workplace environments, employment practices, records, and facilities at any time to ensure they are operating at a level meeting or exceeding Calibre’s high standards.

California Proposition 65 Statements

All products shipped by Calibre International, Inc. into the State of California are subject to Proposition 65 regulations. Proposition 65 is also known as the The Safe Drinking Water and Toxic Enforcement Act of 1986. Proposition 65 was originally enacted to protect California citizens and the State’s drinking water supply from various chemicals determined by a state agency to cause birth defects, cancer or other diseases or harm. Over 850 chemicals are now included on California’s list of Proposition 65 chemicals. A complete list of chemicals can be found at www.oehha.ca.gov/prop65.

Proposition 65 requires any person or company to give a “clear and reasonable warning” to any individuals before “knowingly and intentionally” exposing them to any of the listed Proposition 65 chemicals during the course of doing business. The regulation includes activities that involve manufacturing, assembling, distributing, storing, selling or any other activity that involves the transfer of consumer products.

This warning must occur unless the person or company can demonstrate that the exposure to the chemical is so small that it causes “no significant risk” or “no observable effect.” For most of the Proposition 65 chemicals, the Office of Environmental Health Hazard Assessment has determined “safe harbor” levels of exposure. As long as the chemical level falls below the “safe harbor” level, no warning is required.

Calibre International is committed to providing high quality, safe products for our customers. We have always and will continue to work with our vendors and suppliers to ensure all raw materials purchased from them will meet Proposition 65 standards. In addition to Proposition 65 compliance, Calibre has also instituted testing and documentation procedures to help ensure that all of our products comply with all federal and state requirements.

Companies are becoming increasingly vulnerable to lawsuits relating to Proposition 65. Any section of Proposition 65 may be enforced by the California Attorney General, local district attorneys, and private plaintiffs filing suits in the public interest. Proposition 65 does not just cover items manufactured in California. It covers all products entering California. Businesses located outside the state that ship products to California fall under the regulation.

Calibre’s efforts have primarily focused on the third party testing for signs of lead content in our products. Lead has traditionally been the primary concern for our customers and the main focus of Proposition 65 litigation. Our third party testing is designed to confirm that the product’s lining and exterior meet “safe harbor” requirements for lead content that have been accepted by Proposition 65 and California courts.

Calibre cannot test every piece of product it ships into California and has not tested its products for every one of the over eight hundred and fifty Proposition 65 chemicals in addition to lead. Because of this, our customers may have some concern regarding Proposition 65 compliance. One option to ensure compliance is to include a label on all products that may ship to the State of California. The label would state the following:

WARNING: This product contains chemicals known to the State of California to cause cancer, birth defects or other reproductive harm.

Please contact a Calibre Representative for more information on Proposition 65 and Calibre’s compliance program.

Statement of Lead Content in Inks

Calibre International is committed to providing high quality, safe products for our customers. Calibre is continually working with our vendors to ensure all materials used in the production of our products meet all federal and state health and safety standards, including California Proposition 65.

Calibre purchases inks and other supplies from a number of suppliers throughout the United States. Our ink suppliers have conducted extensive testing to document the lead content for all ink systems we currently use to decorate our products. The lead content of all the inks Calibre uses meet all current local and federal regulations. Testing data is available upon request.

CPSIA Compliance

Calibre International has developed a comprehensive program to ensure products manufactured for our company comply with the The Consumer Product Safety Improvement Act (CPSIA) of 2008. Calibre’s CPSIA program includes testing for all CPSC-regulated standards applicable to our products, including lead content and lead in substrates, products containing certain phthalates and lead in paint and surface coatings.

Certain sections of the law do pertain to the Promotional Products Industry, specifically to those items classified as Children’s Products. All the items found in the High Caliber Line catalog are designed to meet applicable Federal and State regulations. However, the items found in the High Caliber Line catalog are not designed for, or intended for use by children. Despite this, Calibre has undertaken testing campaigns to ensure that certain products that may appeal to children meet CPSIA requirements.

Calibre utilizes accredited third party testing labs. These testing labs issue certificates to substantiate that the tested products meet all applicable CPSIA requirements. These test reports can be found at www.highcaliberline.com. Calibre International also maintains General Certificate of Compliance (GCC) forms for all products in our line that may appeal to children as well as products requiring general certification.These forms can also be found at www.highcaliberline.com.

Depending on what is reasonably practical, Calibre satisfies the tracking label requirement by providing compliant tracking information on either individual item labeling or more commonly on packaging.

Though some CPSIA issues remain open and fluid, Calibre wants to assure our customers that we are vigorously pursuing compliance with not only CPSIA, but all federal and local regulations and that we have a comprehensive testing and documentation program in place.