A&J Import & Export Co.Limited/Pulate Footwear Limited

Code Of Conduct

Employment and the Workplace Equal Employment Opportunity/Nondiscrimination All terms and conditions of employment are not based on personal characteristics or beliefs, but based on an individual's ability to do the job. We provide employees with a working environment free of discrimination, harassment, intimidation, or coercion relating directly or indirectly to race, religion, sexual orientation, political opinion or disability. Forced Labour We do not use any prison, slave, indentured, or forced labor in the manufacture of any of our products. Child Labour We do not utilize child labor in the production of any product. We do not employ any person under the age of 15 (or 14 where local law allows), or the age at which compulsory schooling has ended, whichever is greater. Hours of Labour Our regular working hours is eight hours a day, with two days off work in one week. Coercion and Harassment We acknowledge the value of our staff and treat each employee with dignity and respect. We do not use cruel and unusual disciplinary practices such as threats of violence or other forms of physical, sexual, psychological, or verbal harassment or abuse. Compensation We fairly compensate our employees by complying with all applicable laws, including minimum wage laws, or the prevailing local industry wage, whichever is higher. Health and Safety We maintain a safe, clean and healthy environment in compliance with all applicable laws and regulations. We provide adequate medical facilities, clean restrooms, reasonable access to potable water, well-lit and ventilated workstations, and protection from hazardous materials or conditions. The same standards of health and safety are applied in any housing we provide for our employees. Concern for the Environment We manufacture our products in accordance with all applicable environmental laws and regulations. Ethical Business Practices Sensitive Transactions It is our policy to prohibit employees from entering into sensitive transactions -- business dealings generally considered to be either illegal, immoral, unethical, or to reflect adversely on the integrity of the Company. These transactions usually come in the form of bribes, kickbacks, gifts of significant value, or payoffs made to favorably influence some decision affecting a company's business or for personal gain of an individual. Commercial Bribery We prohibit employees from receiving, directly or indirectly, anything of value in return for using or agreeing to use his or her position for the benefit of that other person. Similarly, commercial bribes, kickbacks, gratuities and other payoffs and benefits paid to any customer are prohibited. However, this does not include expenditures of reasonable amount for meals and entertainment of customers if they are otherwise lawful, and should be included on expense reports and approved under standard Company procedures. Accounting Controls, Procedures and Records We accurately keep books and records of all transactions and the dispositions of our assets as required by law, as well as maintain a system of internal accounting controls to ensure the reliability and adequacy of our books and records. We ensure only transactions with proper management approval are accounted for in our books and records. Use and Disclosure of Inside Information We strictly prohibit disclosure of material inside information to persons within the company whose positions deny access to such information. Inside information is any data that has not been publicly disclosed. Confidential or Proprietary Information We take extra care to keep our customers' trust and confidence in us. Thus, we prohibit employees from disclosing confidential or proprietary information outside the Company that could be harmful to our clients, or to the Company itself. Such information may only be shared with other employees on a need-to-know basis. Conflicts of Interest We designed our policy to eliminate conflicts between the interests of employees and the Company. Since it is difficult to define what constitutes a conflict of interest, employees should be sensitive to situations which could raise questions of potential or apparent conflicts between personal interests and the Company's interests. Personal use of Company property or obtaining Company services for personal benefit may constitute a conflict of interest. Fraud and Similar Irregularities We strictly prohibit any fraudulent activity that might injure our customers and suppliers, as well as the Company. We follow certain procedures concerning the recognition, reporting and investigation of any such activity. Monitoring and Compliance We adopt a third-party monitoring program to confirm the Company's compliance with this Code of Conduct. Monitoring activities may include announced and unannounced on-site factory inspection, review of books and records relating to employment matters, and private interviews with employees. Inspection and Documentation We designate one or more of our officers to inspect and certify that the company's Code of Conduct is being observed. Records of this certification shall be accessible to our employees, agents, or third parties upon request.