WRAP Manual English

WRAP MANUAL NOMAN TERRY TOWEL MILLS LTD.

Approved by

: ………………..………….. Managing Director

Date of Issue

: .…12-03-2013…………………………

Date of amendment

: …New…………….……………

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Table of Contents

Sections

Table of contents

Page

1

Table of contents

2

2

3

General Introduction 3

The Policy of Noman Terry Towel Mills Ltd.

4

Social Management Systems Policies & Procedures 1 2 3 4 5 6 7 8 9 10 11 12

Compliance with laws and workplace regulations Prohibition of Forced Labor Prohibition of Child Labor Prohibition of Harassment or Abuse Compensation and Benefits Hours of Work Prohibition of Discrimination Health and Safety Freedom of Association and Collective Bargaining Environment Custom Compliance Security

5-6 7-8 9-10 11-12 13-14 15-18 19-20 21-25 26-27 28 29-30 31-32

Security ( Policy of Security ) Job Description of Security Guard Factory Safety & Others Committee Fire Fighting / Emergency Team

33-37 38 39 40

Annexure 1 2 3 4

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1. General Introduction: Noman Terry Towel Mills Ltd. is a private limited company having registered office at Dhaka in order to exhibit the effectiveness of its policies and Procedures towards the compliance of lawful, human and ethical working conditions. This is controlled document and is available for reference to all interested parties. The company was established in the year of 2008and situated in the following address:

NOMAN TERRY TOWEL MILLS LTD. Vawal Mirzapur, Gazipur, Bangladesh 1.1 Purpose This policy and Procedure Manual (PPM) relates to the activities initiated during worker employed. Working environment, local law, compensation & benefits, health & safety and subsequent activities including the acceptance of the local government & international labor law and completion of contracts. The (PPM) is established in compliance to the requirements all across the company as mentioned above. The PPM also aims to enhance workers satisfaction and to meet the applicable regulatory requirements.

1.2 Scope The Scope of the business is manufacturing and export of garments. 1.3 Objective The Managing Director carries prime responsibility for the operation and regular formal review of the policy and procedure manual (PPM) to ensure that the company’s policies are effective and targeting to meet the lawful, human and ethical working conditions at all times.

1.4 Distribution: This policy Procedure manual (PPM) is issued on the authority of the Managing Director and is distributed as follows: Holder

No. of copies

Chairman

1

Managing Director

1

Director

1

ACEO & COO

1

General Manager (Production)

1

Asst. General Manager, compliance

1

For the purposes of third party assessment the certification body will be provided with a controlled copy of this manual. Which will be maintained by the Management Representative Asst. General Manager (Compliance.)

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1.5 Security Status This document contains no commercially sensitive information in order to ensure its widest understanding and use.

The Policy of Noman Terry Towel Mills Ltd. •

Social responsibility and working conditions are of fundamental importance to successful business strategy.

•

Workers are the most important factor in our business and we have to meet and keep our commitment towards our workers by complying with all local laws and regulations in all locations where business is conducted

•

We have to abide by the statutory and regulatory requirements in order to contribute positively towards our country and to our workers through following coordinated efforts. 1. 2. 3. 4.

We condemn Child labor. We condemn bonded labor and forced labor. Health and Safety also co-operative working relationship among Employees and employer. Encourage Freedom of association and employees participation at all Level.

5. We condemn discrimination on any ground. 6. Ensuring applicable requirements of laws & workplace regulations. 7. We are strongly maintained Working & OT hours within limit of country laws. 8. We provide all the compensations& benefits. Allowances to our Workers as rules.

defined in local laws

9. Strongly prohibition of Harassment or Abuse. 10. Environment: Our factory and working environment is more hygienic and safe because our factory have big air existing fan in each floor. House keeping is tidier. Toilets are very clean with tiles. Drinking water is available. Sufficient cleaners and sweepers are provided for Cleaning. 11. Custom compliance: we are maintaining as per complies with all applicable custom particular established and complies with laws regarding legal transshipments. 12. Security: we have strong security policy and group such as security Guards has been established only for strong surveillance at all access points to increase deterrence of criminal act. Visitors In- Out every record maintained with register And Visitor carry out the company visitor card. We also provided hand Metal detector.

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Title

Compliance with Law and Workplace Regulations.

Reference

Principle-1

Issue Date:

1st January, 2013 Applicable Law

Bangladesh Labor Code 2006 Environmental Law Customs Law

01. Policy: Noman Terry Towel Mills Ltd. continuously updates it self and complies with local and national laws and regulations including workers & buyers requirements related to all workplace regulations and social laws including environmental regulations, custom laws and security.

02. Procedure: General: Updates the policies and procedure Manual for all changes in laws and regulations to labor practices, factory conditions and environmental and customs compliance. Designated an employee with responsibility for incorporating changes laws regulations in Facility procedures.

03.Responsibility, authority and communication: 3.1: ____________________________________________ of Noman Terry Towel Mills Ltd. an expert of labor laws. The Company always takes support from her for understanding and implementation of any amendment or any new requirement in the local laws. 3.2: For Environmental requirements, GM Admin and Head office seeks updates from Environmental Ministry. Commercial Manager coordinates with freight forwarding agency/shipping agency to seek the necessary information related to current applicable laws and practices which needs to be fulfilled either at the factory premises or at the port, similarly laws and regulations related to labor practices, factory conditions, and environmental and customs compliance.

3.3: Responsibility and authority Asst. General Manager (HR & Compliance) WRAP MANUAL

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Responsibilities: collect all necessary documentation /paper/gazettes of local laws and regulations as well as international issues that are relevant. Updates the policies and procedures manual for all changes in laws and regulations related to labor practices, factory conditions, and environmental and customs compliance. Inform & collect any changes to laws & regulations related to labor practices, factory conditions and environmental and custom compliance by the local government. Make written procedure that outline how & regulations in facility manual & procedure by through staff circulars training session’s e-mail & notice. Promptly incorporates changes to laws & regulations in facility manual & procedure through staff bulletins training session E-mail & notice. 3.4: Communication &Training: Staff workers shall be communicated issues related in compliance to the country laws & regulations through formal and informal communications. Where required HR, Admin & compliance officer will train the designated persons to ensure the compliance of updated laws. Training records are maintained in the form of training attendance. HR, Admin & compliance Officer also provides the relevant training materials pertaining to the new or amended laws to concerned designation. 04.In causes where the new or amended law has direct impact on the workers, they are informed about the requirement or change in company polices or procedures through displaying the company polices, procedures, new or amended local laws on notice board maintained near the main gate /working floors and PA system.

End of the Procedure

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Title

Prohibition of Forced Labor.

Reference

Principle-2

Issue Date:

1st January, 2013

Applicable Law

Bangladesh Labour Code 2006

01. Policy: Noman Terry Towel Mills Ltd. does not use involuntary or forced labor indentured bonded or otherwise does not support the use of forced or compulsory labor in any form including bonded, forced and/or compulsory prison labor. Noman Terry Towel Mills Ltd. Prohibits all relevant individuals from forced employees in any way or unnecessarily limiting employee’s freedom of movement. The company does not require employees to submit originals of documents at the time of employment or during the period of his employment with the company. 02. Procedure: General 2.1: Maintains employment application and service contract to include statement applicant are seeking employment voluntarily and are not under threat or any penalty and to be signed by each applicant application and service contract copies are maintained in the employee’s personal file. 2.2: Issues compensation directly to worker as mentioned in their contract company makes sure that the correct payment is paid to the worker as agreed. 2.3: Job descriptions of security staff has been defined, limiting security tasks to normal security matters such as the protection of property or personnel. 2.4: At the time of hiring HR officer, compliance/Department Heads ensures that the employee signs no bond as a token for continued employment 2.5: Original documents are only asked from the employees for the verification of photocopies of documents and after verification; original documents are returned to the employees. 2.6:During the time of employees interview, the potential candidate is briefed about the fact that he/she is under no compulsion to join the company and similarly he/she is free to disassociate with company as per his/her own free will at any given time but under compliance with the rules as agreed in the appointment letter. WRAP MANUAL

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2.7: GM, HR, Admin&Compliance ensure that workers who are doing overtimes are under no pressure or threat from their departmental Head for compulsory OT. 2.8:In case where any employees decides to leave the company, compliance officer ask about the reason (s) of leaving in order to make sure that he/she is not leaving under unlawful compulsion or threat. 2.9: HR, Admin & compliance officer and all departmental Heads are responsible for communicating deploying and monitoring the practice of effectively prohibiting in voluntary or forced labor. 2.10: HR, Admin & compliance officer trains all departmental heads of the LTD. policies and procedures prohibiting involuntary or forced labor.

NOMAN TERRY TOWEL MILLS

2.11:Suggession boxes placed in the facility, if any employee wants report any incident he/she can use the suggestion box without mentioning his/her identity. The matter will be investigated and resolved by the company after discussing the complaint with managing director (if needed). 2.12: Admin and compliance officer ensures continuous communication between and management through designated members of different committees. The issues related to the workers are communicated to the management for effective, corrective and preventive measures. 2.13: Responsibility/authority and communications: The HR, Admin &compliance officers are responsible for implementation of the principle. Responsibilities: Proper communication of company’s prohibition of forced labor policy to the respective supervisors and workers. Organizing meetings and training programs to ensure that the policy is properly communicated and understood the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list. In case of any incident is reported either through suggestion/complaint box or directly through workers Admin & compliance officer will immediately take the matter (s) to the top management for immediate rectification and necessary action. 2.14: Communication & training: Where required HR, Admin & compliance officer will train the designated persons to ensure the compliance of updated laws. . # End of procedure #

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Title Reference Issue Date

Prohibition Of Child Labor Principle-3 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006 01.Policy: Noman Terry Towel Mills Ltd. will not employ any person below the age of 18 years in any of its departments. Noman Terry Towel Mills Ltd. does not support use the child labor and below 18 years of age no below young workers to be employed in any of its suppliers. Noman Terry Towel Mills Ltd. will discontinue business relations with such supplier who use child labor or continued to do so even after insistence by Noman Terry Towel Mills Ltd. for remediation of child labor. 02.

Procedures:

General: Documents of Age verification: HR department ensures that the following documents are maintained in all the personal files of staff and workers whether directly employed or indirectly copy of education certificate or doctors age estimation form. Verification of Documents of authenticity: At the time of hiring for direct/indirect employment HR& Admin department verifies the photocopies against their original documents.

Hiring process for permanent staff: Hiring process for permanent employees (Staff and workers) at Noman Terry Towel Mills Ltd. Comprises of the following steps. Submission of signed or thumb marked job application (in English or Bengali) Interview by the Head of HR department, DGM and MD (if required) suitability of the person in terms of skills, technical expertise and work experience. Filling of employee profile/application HRD. Review of necessary documents, e.g. Birth certificate, academic certificates, and work experience certificate, union Perished chairman certificate also the Voter I/D card etc.

3.Responsibility and authority: 3.1: The HR Dept. is responsible for implementation of this principle. 3.2: Communicating, deploying and monitoring the above practices in the factory.

4.Communicating and training: WRAP MANUAL

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4.1: Where required, HR, Compliance &Admin Dept. will train the designated persons to ensure the compliance of updated laws.

# End of the procedure #

Title Reference Issue Date

Prohibition Of Harassment or abuse Principle-4 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006 01.Policy: Noman Terry Towel Mills Ltd. does not engage in or support the use of Corporal Punishment, mental or physical coercion and verbal abuse. Noman Terry Towel Mills Ltd. promotes work environment in which no form of harassment is used by its supervisory staff towards the workers particularly female. NOMAN TERRY TOWEL MILLS LTD. discourages use of any form of verbalism or gestures regarding sexual harassment towards its female staff and workers. NOMAN TERRY TOWEL MILLS LTD. abides by and follows legal disciplinary laws and procedures when the need for disciplining any worker arises. Under no circumstances will the concerned manager or section in charge resort to using physical means to punish any worker. 02. Procedures General 2.1: Events requiring disciplinary action: Following events can form the basis of initiating disciplinary actions against all employees. --Breaking the company rules. --Use of abusive language and vulgar actions. --Physical punishment and mental coercion. --Sabotage to company property and product. --Creating an environment of unlawfulness or unrest among the employees. --Failure to follow company’s rules and regulations on regular basis. --Disclosure of company’s proprietary information. --Misbehaving with superiors and fellow workforce. --Harassing fellow workforce particularly females. 2.2: In cases if an employee is found to be involved in any event as identified above, respective section supervisor will do the counseling with the worker and try to identify the reasons, which cause any disciplinary action by the worker and verbally instruct the worker to mend his/her ways. 2.3: On the other hand if any in-charge or supervisor is found to be involved harassing or abusing the workers, the HR Officer, Compliance & Welfare officers will do the counseling and try to identify the reasons, which may cause any disciplinary action. WRAP MANUAL

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2.4: NOMAN TERRY TOWEL MILLS LTD. is committed to comply with applicable health codes to reasonably accommodating the preference of both smoking and non-smoking employees. For reasons of safety, public relations and other concerns use of tobacco in the workplace is strongly prohibited. NOMAN TERRY TOWEL MILLS LTD. prohibits the unlawful manufacture. distribution, dispensing, possession or use of contraband substance in the workplace Violation of this policy management will take the disciplinary action against of that employee. 2.5: GM, HR, Admin & Compliance ensure the minimum wage as per local laws for all employees whether directly indirectly employed. 2.6: Suggestion box is also placed in the facility, if any employee wants to report any incident of harassment or abuse he/she can use the suggestion box to lodge his/her complaint without mentioning his/her identify. The matter will be investigated and resolved by the company after discussing the complaint with Managing Director. (if required) 03. Responsibility, authority and communication: The GM, HR, Admin & Compliance is responsible for implementation of this policy. Responsibilities: Proper communication of company’s policy on harassment abuse corporal punishment and signing of affirmation statement acknowledging the understanding from the respective supervisors. Organizing meetings and training programs to ensure that the policy is properly communicated and understood the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list In case of any incident is reported either through suggestion/complaint box or directly through workers authority will immediately communicate the matter (s) to the top management for immediate rectification and necessary action. Communication and training: Where required HR, Welfare and compliance officer will train the designated persons to ensure the compliance of updated laws. .

# End of the Procedure # WRAP MANUAL

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Title Reference Issue Date

Compensation and Benefits Principle-5 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006 Policy: NOMAN TERRY TOWEL MILLS LTD. Pays at least the total minimum compensation required by local laws. Including all mandated wages, allowances and benefits to its workers and staff. NOMAN TERRY TOWEL MILLS LTD. . does not pay less than the minimum wage prescribed by the local law to unskilled workers. To other Category of workers, wages paid will be in line with those prevailing in the industry at the time, which also provides some discretionary income. NOMAN TERRY TOWEL MILLS LTD. . Posts legal minimum wage rates, Overtime rates, benefit policies and additional payment information in the native language.

Procedure General 2.1: Under supervision of General Manager, Company’s account department ensures the compliance against this policy. 2.2: Company makes sure that Salaries of employees are not deducted as a matter of punishment imposed from any superior to subordinate. 2.3: Companies reviews, if any complaint, objection is lodged raised through suggestion memo and discusses the matter with management and resolved it on priority basis. Salary: • Company makes sure that all the salaries of permanent employees are in accordance with the labor law and disbursed through an adequate procedure on given schedule. Grade Designation Basic Salary House Rent Medical Conveyance Total Salary 35% of Basic

01 Sr. Operatior 3589 1256.15 300 100 5245.15 02 Operator 3278 1147.30 300 100 4825.30 03 Jr. Operator 3122 1092.70 300 100 4614.70 03 Asst. Operator 3122 1092.70 300 100 4614.70 Pay days: Salary will be paid within the seven working days of the next month. Each salary will include earnings for all work performed through the end of the previous payroll period. Over time will be paid on same date of salary. In the event that a regularly scheduled payday falls on a day off such as a holiday, employees will be paid on the first day of work following the regularly scheduled payday in working time. • Salary of the workers includes all allowances as admissible under the law.

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• If a regular pay day during an employee’s may receive his or her earned wages before leaving for vacation if written request is submitted at least one week prior to departing for vacation. Over time: Correct recording of OT work will be ensured and payment calculation for OT work will be double the rate of wage.

OT =

Basic × 2 (Double) × OT hrs

208 (26 days × 8) Bonus: Company makes sure that all the permanent employees receive bonus on time such as attendance bonus. Group incentive bonus or any other declared by authority. All employees will be considered for payment of bonus (festival). They will be paid bonus if completed at least Nine (9) months continuous service. The bonus will be 60% of basic salary. Deduction: We don’t agree any Kind of deduction but if any body unauthorized leave or intentionally absent than as per the absent days will be deducted from the basic salary by law. Responsibility and authority and communication: Responsibility and authority: The Admin, HR, Compliance dept & Accounts Manager are responsible for implementation of this principle. Responsibilities: Proper communication of company’s policy on minimum wages. Overtime compensation rates legally mandated benefits and additional payments to all employees. Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meetings are than recorded and circulated to all the participants as per distribution record list. 6. Communication and training: 6.1: Where required, Compliance Officer will train the designated persons to ensure the compliance of updated laws. 6.2:Salary , Over time & other payment record will keep at least for 12 months..

#End of the Procedure#

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Title Reference Issue date

Hours of work Principle-6 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006

Policy : NOMAN TERRY TOWEL MILLS LTD. informs all prospective employees, at the time of hiring, the policies and procedures and legal limitations on the maximum number of hours of work per day, week and months both regular and overtime and the maximum number of consecutive days they can legally required to work. NOMAN TERRY TOWEL MILLS LTD. . ensures the hours worked each day and the days worked each week do not need the legal maximum. NOMAN TERRY TOWEL MILLS LTD. Provides one day off in every seven-day period except as required to meet Business needs. NOMAN TERRY TOWEL MILLS LTD. Implements a regular work day of 08 hours. NOMAN TERRY TOWEL MILLS LTD. has an organized system of record keeping. The time recording systems mordered and effective. NOMAN TERRY TOWEL MILLS LTD. defines the regular overtime requirements as maximum-2 hours day. NOMAN TERRY TOWEL MILLS LTD. defines “urgent business need” as if workers are engaged in overtime on day and gazette holidays. They are paid overtime for the day as well as given a compensatory leave as soon as possible. NOMAN TERRY TOWEL MILLS LTD. allows employees legally required or contractually agreed rest breaks entities whether they are compensated. NOMAN TERRY TOWEL MILLS LTD. defines the normal workweek as 06 days from Wednesday to Monday and signets days off for rest as Tuesday. NOMAN TERRY TOWEL MILLS LTD. designates days off for legal holidays as per gazette holidays.

Procedure Normal working hour NOMAN TERRY TOWEL MILLS LTD. maintains the following working hour:

Wednesday to Monday 08.00 am 05.00 am. One hour break for lunch and prayers. Friday is general holiday. The GM, HR,Admin & Compliance is responsible for ensuring all prospective employees are made aware at the time of hiring of legal limitations and the company expectations pertaining to hours of work and days of rest. HR, Admin and Compliance officers/Departmental Heads ensure that under normal circumstances, no worker spends more than 08 hours at work per day or 48 hours per week. Every employee show WRAP MANUAL

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Proximity card at Proximity machine /respective time card to timekeeper when enters into factory premises. Similarly Every employee when goes out from factory, again show Proximity card at Proximity machine/ collects his/her respective time card from timekeeper. Leaves/Holidays: Besides allowing all gazette holidays the company also grants to employees with following type of leaves. Annual Leave: (AL) Entitlement: Every employee will be entitled to Annual leave after completion of one-year service, which is calculated as one day off each 18 days working basis. Utilization: The Al Earned during one service year will be available for utilization in the following service year. This Arrangement will continue during the total period of employment. Casual leave (CL): Entitlement: Every employee will be entitled to ten days Casual leave per calendar year. Utilization: The CL earned during the calendar year has to be utilized within that year and will not be carried over to the next year in any case. Festival leaves: Entitlement: Every employee will be entitled minimum to Eleven days Festival leave per calendar year. Utilization: The FL earned during the calendar year has to be utilized within that year and will not be carried over to the next year in any case. Sick Leave: Entitlement: Every employee will be entitled to fourteen (14) days SL per calendar year. Utilization: The SL earned in the calendar year has to be utilized within that year and will not be carried over to the next year in any case it will be full paid. Maternity Leave (ML): Entitlement: Any female employee with a minimum of six months of uninterrupted service in the organization shall be entitled to maternity leave. Utilization: Eight weeks before and Eight weeks after consecutive days with pay ( as per law ) . Over time Hours: Saturday -Thursday 05.00 p.m – 07.00 p.m. Two hours (if needed) Overtime working: On any working day, whenever department Head feels the need to go for overtime production in order to meet the production/ shipments targets, He/She fills the overtime sheet by identifying the persons for overtime, duration of overtime activity to be done during overtime and send to General Manager. Admin, HR & compliance Manager verifies the allowable hour’s limits for each worker identified on the time cards. In case if Admin & HR Manager does not allow any worker to cross limits of 12 hours in a week. Administrative approval is taken from Managing Director. Compensation of overtime working:

HR & Admin General Manager makes sure that overtime charges are paid at double the agreed rate with the monthly basic salary of the employee. Willingly overtime by workers: The HR, Admin & compliance General Manager strictly monitors the willingness of all those employees. Who usually do the overtime activity and without will/wish of any employee does not engage him to be at overtime for any reason.

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Working due to urgent business needs:

NOMAN TERRY TOWEL MILLS LTD. Can go for production on holidays in case of following business circumstances. Any external unplanned failure, which can stop the production operations.

Admin, HR& compliance officers makes sure that in cases where the company operatated on Holiday Thursdays workers will be given one day off as soon as possible on either side. The Admin department is responsible for communicating deploying and monitoring defined “urgent business needs” requirements. Responsibility, Authority and communication:

Responsibility and authority The General Manager, HR, Admin & Compliance is responsible for implementation of this principle. Responsibilities: The HR Dept. and all relevant individuals, including all individual responsible for the hiring process, on the NOMAN TERRY TOWEL MILLS LTD. requirement to ensure all prospective employees are made aware at the time of hiring of legal limitations and NOMAN TERRY TOWEL MILLS LTD. expectations Pertaining to the maximum number of hours of work per day, week and month, and the maximum number of consecutive days the employees will be expected to work. The facility documents the details of the training session, including date of session, names of individuals trained and the nature of the training content. The HR, Admin & Compliance officer trains all relevant individuals, including all individuals responsible for production coordination and Scheduling, on the NOMAN TERRY TOWEL MILLS LTD. there to their definition of “urgent business needs” NOMAN TERRY TOWEL MILLS LTD. documents the details of the training content. The HR manager is responsible for posting the legal maximum regular and over time hours and days rest information in the native language of the NOMAN TERRY TOWEL MILLS LTD. Workers and management personnel. HR officer, welfare officer & compliance officers is responsible for communicating. Deploying and monitoring the practice of ensuring all work is performed in the factory and employees do not work more then regular or overtime hours per day, week or month. HR Officer, Welfare Officer & Compliance Officer train all relevant individuals. Including all individuals responsible for procedures related to maximum number of regular and overtime hours and required days of rest NOMAN TERRY TOWEL MILLS LTD. . documents the details of the

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training session including date of session names of individuals trained and the nature of the training conducted. Communication and training: Admin, HR, welfare & compliance officers will train the designated persons to ensure the compliance of updated laws.

# End of the procedure #

Title Reference Issue Date

Prohibition of Discrimination Principle-7 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006

Policy: NOMAN TERRY TOWEL MILLS LTD. is an equal opportunity employer and believes in equal opportunity for all based on merit and ability to carry out the given responsibilities. It believes in equal pay for similar jobs and provision of equal opportunity to all employees to enable them to grow with the company. NOMAN TERRY TOWEL MILLS LTD. does not discriminate against anyone when hiring, promoting, pay selecting people for training, at the time of termination of employment or retirement on the basis of religion, race, national origin, disability, gender, any association or political affiliation. NOMAN TERRY TOWEL MILLS LTD. does not carry out any mandatory pregnancy test at the time of hiring of any female worker.

Procedures: Equal opportunity Employer: Equal employment opportunity applies to all aspects of employment practices including recruiting hiring placement promotion demotion (If any) transfer training compensation benefits and termination. Company ensures that all the employees whether employed directly or indirectly are employed solely on the basis of merit and no discrimination is made on the basis of race, religion and gender. Company ensures that to the extent possible any vacant position is advertised either through newspaper or any other appropriate means. In cases where any female seeks employment, Company ensures that she is not discouraged for employment due to fear of maternity leave or any other reason. It is also ensured that female employees are not made to go through pregnancy testing. In cases where the potential candidate is disabling but his/her disability cannot affect the nature of job for which he/she is seeking employment, the company does not discourage these employees and provide them equal opportunity to seek employment on merit. Company ensures that in cases, where for the same time of job, male and female employees both are employed, they are hired on equal salary structure and company benefits and without any discrimination. WRAP MANUAL

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All staffs (Supervisor and above) sign and undertaking that they have understood the policy on discrimination and that if found guilty they can lose their job.

Reporting on discriminatory Behavior: In cases where an employee feels that he/she is treated with discriminatory behavior, he/she is encouraged to report such events to the authority. Employer investigates the event of the employee’s complaint. Where it is found that a severe incident of discrimination has taken place. Company records his observations and forward to Managing Director who decides due action. Based on the objective evidences available and from the feed back of other worker as well as on the past discriminatory behavior, General Manager may decide the following. -Terminate the worker -Demote him/her. -Retain him/her with last warning. Results of investigation and actions decided will be filed in the personal file of particular employee. Suggestion box is placed in the facility if any employee wants to report any incident he/she can use the facility without mentioning his/her identity the matter will be investigated and resolved by the company after discussing the complaint with production HR Admin and Compliance department.

Responsibility, Authority and Communication: The HR manager is responsible for that. Proper communication of company’s policy on discrimination. Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are than recorded and circulated to all the participants as per distribution sheet list. Communication and training: Where required HR officer, Welfare officer, Admin officer & Compliance officers will train the designated persons to ensure the compliance of updated laws. .

# End of the procedure #

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Title Reference Issue Date

Health and Safety Principle-8 1st January, 2013 Applicable law

Bangladesh Labor Code-2006

Policy : NOMAN TERRY TOWEL MILLS LTD. . Utilizes all available resources to provide a Healthy and safety working environment for all its workers and to eliminate all potential hazards that are capable of causing work related accidents. NOMAN TERRY TOWEL MILLS LTD. through a systemized mechanism detects potential risk and hazards associated with the job or present in the work environment, which could cause harm/injury to the workers. NOMAN TERRY TOWEL MILLS LTD. Provides a medical centre there is one Doctor and One Nurse for full time. NOMAN TERRY TOWEL MILLS LTD. provides all necessary personal protective equipments and implements controls to ensure to safety of the workers and their health.

Procedures: General: NOMAN TERRY TOWEL MILLS LTD. is providing first aid and emergency of any injury accident and normal treatment for all employees free of cost regularly. To assist in providing a health and safety-working environment for employees, customers and visitors, this is a top priority for NOMAN TERRY TOWEL MILLS LTD. Fire fighting team (FFT) is formed Floor wise combining Fire Fighting, Fire Rescue & First Aid, to induce workers to take active part in the work place safety programs Members of Fire Fighting Team are 720 person. Fire Officer (Trained by Fire Dept.) is the team leader. The minutes of the (FFT) meetings are to be recorded and distributed among the members. Company makes sure that fire extinguishers are all available and all the employees are well trained to use these. Company keeps fire extinguishers location list in a file, which contains location identification number of fire extinguisher of refilling date and expiry date. This list is frequently updated as any fire extinguisher removed form the dedicated location either for refilling or due to any other reason. Regular fire drills and training are conducted. Involving every department or monthly basis. Admin staffs, Compliance Officer will ensures that all workers are provided with personal protective equipment where necessary and provided basis training for usage of such equipment.

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Admin staffs/compliance officer ensures through maintenance staff that needle guards, eye guards, pulley guards are properly installed on all the machines. Doctor room and first aid boxes are provided to workers. In case of any injury, first aid is provided to employees by training of first Aiders / Medical assistant or Doctor. NOMAN TERRY TOWEL MILLS LTD. . has all permanent employees completely insured a required under local laws. NOMAN TERRY TOWEL MILLS LTD. . has professional Medical Officer and medical assistant (nurse) to provide first aid assistance to workers and arrange trainings on emergency first aids and conduct training for Fire fighting by expert. Each employee is expected to obey safety rules to exercise caution in all work activities. Employees must immediately report any unsafe condition to the supervisor, Employees who violets safety standards, who cause hazardous or dangerous situations, or who fail to report or, where. Appropriate, remedy such situations, may be subject to disciplinary action, up to and including termination of employment. Emergency Procedure: Emergency: It is defined as “sudden happening demanding immediate action/response for intraco, some of the emergency conditions may be due to the following: Fire/smoke: Accidental release /discharge of environmentally hazardous material. Industrial accident: All natural calamities as Earthquake, Tornado, Incessant Rain etc. In this situation we have a very strong emergency team functioning which is mentioned below flow- chart. Flow chart of emergency team: Anexure-5 Response to Emergency: In case of emergency due to the above-mentioned conditions, the response of the factory personnel should be as per the following procedures On of discoverer: A person who first detects any of the above mentioned conditions of emergency or any other unusual condition, which can be assessed as the reason for emergency condition. First inform the area supervisor informs the security guard informs the emergency alarm responsible person to be ready for supervisor instruction. Action of the Supervisor: On information from the person or worker, Supervisor shall inform the General Manager, Admin officer, Compliance executive, Security In- charge instruct and ensure that alarm goes on if as required. Ensure every one of his areas to proceed to the designated emergency assembly points.

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Actions of the Admin/Compliance General Manager: On information from the supervisor, Admin staffs and Compliance officers inform the Head of Fire fighting team (FFT). Inform fire brigade. Assess the situation the scope of emergency, and coordinate between the supervisors for everyone in the factory to be at the emergency assembly points. Actions of the fire fighting team (FFT) Head: On information and from the Admin or compliance General Manager or as the alarm goes on the head of (FFT) shall respond as per the emergency along with his team. The head of Fire safety team (FFT) has a dedicated shelter (Assembly point) known to every one in the factory. All the personnel are trained, instructed and provided with instructions that on hearing the alarm, they should immediately leave their work, Switch off the machine (if working on a machine) and gather at the designated emergency assembly point. All the departments are provided with respective evacuation plans. Emergency exits and paths to them are elaborately marked on the evacuation plans. Industrial accident: In case of any accident, the discoverer informs the area supervisor immediately. Supervisor access the situation. Casualty is protected from the dangerous area and shifted to a safe place. Supervisors inform the FFT if the accident is major one, supervisor instruct and insure that the emergency alarm goes on. First Aid provided to the casualty. If required the team leader arranges for external medical treatment. Protection Equipment: • Portable and Fixed Fire protection equipment is provided for entire factory areas it consist of fire extinguishers and fire buckets which are available for use before the FFT arrives (provided the associate has been trained in fire fighting operation) • The FFT is responsible for monthly inspection, maintenance and required record- keeping of all portable fire extinguishers and Hose rill, Smoke detector,Fire fighting Instruments. Any used or damaged extinguisher or others should be reported to the FFT leader. Fire extinguishers (portable) • Properly marked or 5kg dry powder fire extinguishers are provided in ample quantity for all the production areas. Fire buckets: • Properly marked fire buckets are provided to all the main production areas or floor stair case. Emergency light: The safety & Health rule requires emergency lighting within facilities at the following areas. •

Emergency lighting is installed in areas where exits would be hazardous during a power failure such as stairs and main departments.

Exits signs: Exits signs are provided in specific locations in building to designate the means of exits from the building. • Must be installed at all required exits doorways and where necessary to indicate clearly the direction of exits. WRAP MANUAL

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• Must be illuminated and also in local language.

Broken Needle procedure: General procedure: 1. Replaced by used needle. 2. Keep record and document properly. Broken needle policy: 1. Broken needle check and confirm all parts of broken are available. 2. If found the broken parts than keep it pest all broken parts in the register. 3. Keep record and documentation properly. 4. If any parts of broken are not found than go for metal detection for whole bundle. 5. If found than replace the needle by taking all needle parts and placing in the broken needle register. 6. If not found then tell all concern peoples for their extra care and 7. Stopped the production at that machine and search around the machine if not found anything then that garment bundle will be marked further with conveyor belt metal detector. 8. Finally this garment bundle will be destroyed and photograph should be taken.

Responsibility, Authority and communication: 1. General Manager /HR, Admin & Compliance is responsible. 2. Providing healthy and safe work environment to the workers. 3. Detecting potential risks and hazards associated with the job or present in he work environment, which would cause harm/injury to the workers. 4. Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list. Communication and training: Where required, HR officer & Compliance Officer will train the designated persons to ensure the compliance of updated laws. Training records are maintained in the form/register of training attendance. # End of the procedure #

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Title Reference Issue Date

Freedom of association and collective bargaining Principle-9 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006 Policy: NOMAN TERRY TOWEL MILLS LTD. recognizes and respects the rights of employees to exercise their lawful rights of free association and collective bargaining. NOMAN TERRY TOWEL MILLS LTD. does not discriminate against employees who form or participate in lawful associations and or collective bargaining. Forms of discrimination include, but are not limited to Wage penalties Suspension Termination NOMAN TERRY TOWEL MILLS LTD. does not illegally discriminate against employees who choose not to join any association or bargain collectively. NOMAN TERRY TOWEL MILLS LTD. . does not discriminate against applicants who have previously exercised their lawful rights of free association and/or collective bargaining.

Procedures: General: 2.1: NOMAN TERRY TOWEL MILLS LTD. . allows freedom of movement during employee breaks unless such movement interferes with the work of other employees. 2.2: NOMAN TERRY TOWEL MILLS LTD. .allows employees to leave the NOMAN TERRY TOWEL MILLS LTD. ground for reasons other than normal security reasons. 2.3: NOMAN TERRY TOWEL MILLS LTD. . acknowledges the right of every employee to from free association or not to do so for collective bargaining. 2.4: In case if employees choose to form free association, they have to follow the legal procedure as laid down in the law for the formation of unions. 2.5: The employees can register themselves as the registered union. However if the other group of employees feels that they do not have the true representation in the registered union, they are free to form another registered union. 2.6: All the registered unions have to follow the following steps before putting any issue related to collective bargaining. • Nomination of union representative through selection or election process. • Development of Memorandum of Association. • Development of charter of demands.

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2.7: If the need arises General Manager, Admin is responsible to liaison between top management and need help formation of authorized body and to chalk down all the activities as per the procedure. 2.8: Worker Welfare/Participation Committee (WWC/WPC) has been formed in NOMAN TERRY TOWEL MILLS LTD. members of committee were elected through hand raising election took place, where nominated names were taken and supportive workers raised hand in favor of the nominee. 2.9: Members of work council are – See annexure-4 2.10: WWC/WPC meetings will be held on monthly basis, chaired by the General Manager . Minutes will be maintained of the proceeding of the WWC by the head of the committee. 11: Minutes of WWC/WPC meeting are maintained and displayed at notice board. 12: Suggestion boxes are placed in the facility, if any employee wants to report any incident he/she can use the suggestion boxes without mentioning his/her identify. HR department is responsible to open the box if any suggestion or complaint is found and bring that issue in the (WWC/WPC) meeting. If required the issue will be discussed with management for immediate rectification. Responsibility, authority and communication: HR & Compliance are responsible for: Responsibilities: Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list. Position in The organization chart of WWC/WPC as bellow: 7: Communication and training: 7.1: Compliance Dept. will train the designated persons to ensure the compliance of updated laws. 7.2: Training records are maintained in the form/register of training attendance.

# End of the procedure # Title Reference Issue Date

Bangladesh Environmental Act

Environment Principle-10 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006

Policy: NOMAN TERRY TOWEL MILLS LTD. . complies with environmental rules, regulations and standards applicable to its processes and practices environmentally conscious practices in its work environment. Where applicable, NOMAN TERRY TOWEL MILLS LTD. . performs initial environmental impact assessment and implements mitigation measures: WRAP MANUAL

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Procedures: General Since the nature of production is mainly contaminated water & stitching with cut pieces of fabric as the main waste. The following industrial waste has been identified: ∗ Solid waste, Water wastes & Chemical waste. Initial environmental Impact assessment: Welfare and Compliance officers seek the updates from different buyers related to environmental requirement for whom NOMAN TERRY TOWEL MILLS LTD. . is working. Compliance Officers ensures the periodical testing of drinking water compares the results against the requirement. Where required Compliance officer identifies the mitigation measures including use of PPE. Mitigation Measures: Based on the status of environmental performance mitigation measures are identified which can be Disposals of fabric, waste and paper by NOMAN TERRY TOWEL MILLS LTD. . to local vendors who use it as a material for re-cycling; The water waste generated from utilities i.e. chemical water, washrooms, water cooler, and abolition area and is discharge into sewerage & ETP system. The workers use dust masks in order to prevent the inhalation of fabric fluff generated from the fabric. Responsibility, Authority and communication: General Manager/ HR Manager/ Admin Manager & Compliance Manager are responsible for that: HR, Admin & Compliance Managers are responsible to implement the policy and ensure that the company complies with national environmental quality standards. Communication and training: Where required, Compliance Dept. will train the designated persons to ensure the compliance of updated laws. Training records are maintained in the form/register of training attendance. # End Of the Procedure # Title Reference Issue Date

Bangladesh Customs Act

Custom Compliance Principle-11 1st January, 2013 Applicable Law

Bangladesh Labor Code-2006

Policy: NOMAN TERRY TOWEL MILLS LTD. complies with all applicable custom laws and in particular established and complies with laws regarding legal transshipments.

Procedures: General: NOMAN TERRY TOWEL MILLS LTD. follows the bellow mentioned export process. - Receipt of orders - L/C is received from buyer to open for import of raw materials. - Preparation of export documents - Clearing the raw materials from customs. - Negotiation - Receipts of export proceeds WRAP MANUAL

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Marketing departments forward purchase orders projection to commercial dept. for further processing. General Manager does planning and evaluates the allocation of orders as per production and co- ordinates with the related personal to starts production according to purchase contract. 4. After completion of production the buyers QC or nominated agent conducts inspection. 5. Booking for export of the goods is given to shipping line by Commercial Department. 6. After final inspection EXPORT from issued by concern bank and custom documents are prepared i.e. invoice, packing list and a set is forwarded to clearing and forwarding agent. 7. Clearing and forwarding agent prepares shipping bill and completes custom formalities and hand over the goods to shipping line or their agent with custom documents. The shipping line/ agent release container for loading and left port for destination. 8. After sailing of vessel, shipping line issued B/L (shipping Documents) and submits to negotiating bank along with invoice, Packing list and other documents as per terms of contact L/C. 9. Receipts of exports proceeds. 10. Finally, follow up with bank for receipt of funds on realization of proceeds file is closed.

Responsibility, Authority and Communication: Commercial Head provides training regarding custom laws or any trade requirement and on amendments and maintain training records. Responsibilities: Related documents -Packing list -Custom invoice -EXP form -Original letter of credit -Commercial Invoice -Bill of Exchange (draft) -Bill of lading -Certificate of origin -GSP form “A” -Beneficiary Certificates -Inspection report Communication and Training: Where required commercial & compliance Dept. will train the designated persons to ensure the compliance of updated laws. Training records are maintained in the form/register of training attendance. # End Of the Procedure #

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Title Reference Issue Date

Security Principle-12 1st January, 2013 Applicable Law Bangladesh Labor Code-2006 Bangladesh Customs Act NOMAN TERRY TOWEL MILLS LTD. maintains vigilant security system to guard against the introduction of non-manifested cargo into outbound shipments. NOMAN TERRY TOWEL MILLS LTD. supports all actions to discourage smuggling of goods and maintains a system to monitor the shipment loading process in the factory premises. Procedures: General The security system developed and implemented at NOMAN TERRY TOWEL MILLS LTD. . consist of PMAC (personal Movement and Access Control) BY CCTV and • The gate keeper to the security room intercepts any one who enters into the factory premises. • Security staff first inquires from the visitor his name, category of visitor’s, supplier, general visitor etc. and whom he wants to see. • Security staff provides the visitor card to visitor for his distinct identification. • Host security personal and the area supervisors ensure that the visitors should only visit the area for which they have been authorized to visit and are escorted by some company representative. • When the visitor leaves the factory premises return to the security staff. • Area supervisors of respective sections and security personal ensure that employee’s movement should remain confined in their respective areas and they should visit other sections only as a part of assigned job/task. Dedicated and locked finished Goods area: • A separate finished goods area is maintained for the storage of pack cartons. • The goods are moved into or from the area in the presence of security personnel. Inspection of container before and after loading: • Shipment Coordinator/Security personnel inspect the container( 7 Points ) when it is docked for loading the container is inspected for cleanliness any unwanted item present in the container. • After the loading, Shipment coordinator/ Security personnel again inspect the container to identify any open carton, any unwanted items present in the container, physical condition of cargo after loading. Bolt Lock has been used. • Inspection record of container for are and post loading is maintained. Monitoring during loading: • Shipment coordinator/security personnel monitor the loading of shipment by ensuring the following steps. -

Only authorized loaders stack the cargo. Loaders are not changed without his information. Loaders do not stay inside the container for longer duration.

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-

Any open carton is not loaded in the container.

Employee’s background check/verification: • At the time of hiring of security and loading workers/staff background check of the potential employee is performed by Admin/HR officers and recorded in employee background verification from and kept in personal file of the employee. • To the extent possible people whose background can’t be verified e.g. new immigrants in the city they are not employed for the jobs related to security Weapons Van: • NOMAN TERRY TOWEL MILLS LTD. provides a safe environment for employee’s volunteer’s clients and the general public. Deadly weapons are prohibited in all corporation facilities. No one may enter any facility operated by NOMAN TERRY TOWEL MILLS LTD. . While carrying deadly weapon concealed or other wise employees who work in the field or perform other work outside of their workstation are prohibited from carrying weapons. Personnel Security: NOMAN TERRY TOWEL MILLS LTD. . will provide a personnel security if required for shifting or any emergency of work at night. Job Responsible of security Personnel: Responsibility, Authority and communication: Admin Manager is responsible to implement the policy on security to ensure that the company complies with the entire local/international laws and regulations. Communication and Training: Admin/compliance dept. will train the designated persons to ensure the compliance of updated laws. Training records are maintained in the form/register of training attendance. # End of the Procedure # Annexure-1 JOB DESCRIPTION OF SECURITY GUARD NOMAN TERRY TOWEL MILLS LTD. Responsibility of Security Guard: 1. Take over his duties before 10 minutes of the start his duties. 2. Check the goods during loading and unloading according to Challan & Gate pass. 3. They will give protection to any unauthorized access at finished Goods zone for misplace carton. 4. Before loading activities they will inspect in side the covered van container for shipment with store incharge, Security in-charge. 5. After loading the cover van container must be inspected checked again whether every cartoon is perfect or not and maintained in the record book. 6. Loading unloading activities will be done by designated loader only. 7. No loader will be changed during loading unloading. 8. Loader cannot stay longtime inside the cover van container during the loading. 9. during loading any open carton cannot be loaded inside the cover van container. 10. All goods will be checked properly during arrival and departure.

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11. The entry is strictly prohibited for unauthorized person. 12. Visitor card must be provided for entry/exit period and also time will be recorded in the register during visit. 13. Properly search the workers during the exit. 14. You must report regarding any kinds of incident/accident to the management. 15. To protect the safety and wealth of company regularly. 16. To ensure the safety of workers during the fire drill. 17. Protect the thief, robbery and any unlawful activities. 18. Memorized the all emergency telephone numbers. 19. They will obey the incase of any extra duties. 20. They will follow the NOMAN TERRY TOWEL MILLS LTD. Security policy Strictly. ∗∗∗ NOMAN TERRY TOWEL MILLS LTD. maintains the following committee: These committees will held formal meeting in a month regarding committee objective, aims, and activities and determined the improvement of the factory employees Safety, Health and Fire Fighting with others compliance issues etc. And all the committees are formed floor wise for easy movement activities.

Health and safety committee NOMAN TERRY TOWEL MILLS LTD. . FACTORY SAFETY COMMITTEE :

a)Advisor committee b)EXECUTIVE COMMITTEE

c)Electrical Safety d) Industrial Safety e) Fire Safety f) Health and Hygiene g) House Keeping h) WWC/WPC commitee

i) Emergency Operation Procedure Of Fire Fighting And Rescue Team i.1 Quickly Fire Bell On: i.2 Call Nearly Fire Brigade And Head Quarter: i.3 At First Electric Main Switch Board Off: WRAP MANUAL

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. i.4 Fire Extinguisher user: i.5 Hose Pipe User: i.6 Rescue Team i.7 First Team i.8 Close Supervison team

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