Spiegel is a leading direct marketer of fashionable apparel and home furnishings. As part of the Spiegel Group, we are committed to providing customers with the highest quality and value in our products. We believe this commitment is best met through strong relationships with our associates and by only selecting business partners who share our ethics and agree to our standards of business conduct.

LEGAL REQUIREMENTS

Our business partners must comply with all applicable legal standards and require ments of the country in which they are doing business, as well as those of the United States.

PRODUCT QUALITY

Our business partners must share our commitment to product quality and to main taining the operating practices necessary to meet our quality standards.

ENVIRONMENTAL STANDARDS

Our business partners must adhere to their national laws regarding the protection and preservation of the environment.

EMPLOYMENT PRACTICES

Our business partners must not utilize child labor as defined by the United Nations standards or by national standards, whichever are higher. They must not utilize forced labor, including prison or other compulsory labor.

WORKING CONDITIONS

Our business partners must share our commitment to providing a safe and healthy workplace and to treating employees fairly and in compliance with local laws. While we recognize that cultural differences exist and standards may vary by country, we expect our partners to adhere to the following:

• Health, safety and other workplace standards must meet all local laws and safety regulations.
  
  
• Worker housing, where provided, must meet the same standards for health and safety as the workplace.
  
  
• Employees must be compensated fairly for all hours worked and at rates that meet local industry standards.
  
  
• Employees must not be discriminated against because of personal character istics or beliefs.

Compliance with these standards is a condition for becoming and remaining a busi ness partner of Spiegel and will be agreed to in writing as a term of engagement. Spiegel will take appropriate action, including termination of our relationship, with any business partner in violation of our standards.

To facilitate effective monitoring and enforcement, our business partners are ex pected to provide full access to their production facilities and to relevant records relating to employment practices. We will undertake affirmative measures, such as on-site inspection of facilities, to implement and monitor these standards.