Code of Conduct

Ethical Sourcing Human Rights Workplace Standards
Last updated: February 18, 2026

Introduction

At FreedomWear Co., we stand firmly against exploitative labor practices. We adopt and expect our partners to uphold strong human rights and workplace standards, and this Code of Conduct is our baseline commitment. This Code applies to FreedomWear Co. employees, representatives, suppliers, vendors, authorized manufacturers, decorators/embellishers, and other business partners involved in producing or delivering our products.

We expect compliance with applicable local laws. Where local law and this Code differ, the higher standard shall apply to better protect workers. We require partners to communicate these expectations throughout their operations and supply chains.

1. Child Labor

No person under 15 years of age—or below the legal age for completing compulsory schooling, if higher—shall be employed. We will not contract with any parties that engage in or permit child labor.

2. Compensation & Wages

Workers shall receive fair payment for regular work, sufficient to meet basic needs and allow some discretionary income. Wages must at least meet the legal minimum or prevailing wage—whichever is higher—and adhere to applicable laws and agreements.

Workers must receive clear, understandable wage information and wage statements. Pay must be made on time and in full.

Where wages fall short of meeting basic needs, suppliers must collaborate with FreedomWear Co. on a plan for progressive improvement.

3. Forced or Coerced Labor

No forced, bonded, indentured, trafficked, or involuntary prison labor is permitted under any circumstances. All employment must be freely chosen, without threat or penalty for refusal.

Workers must be free to leave employment after reasonable notice and must not be required to lodge deposits, surrender identity documents, or pay recruitment fees.

High-risk forced labor regions/materials: FreedomWear Co. will not knowingly source products, components, or materials made with forced labor. This includes avoiding sourcing connected to regions and entities where forced labor risks are elevated, unless credible, verifiable evidence demonstrates forced-labor-free supply chains.

4. Employment Terms & Conditions

Employment terms must be transparent, documented, and compliant with labor and social security laws. Workers shall receive clear written information (in a language they understand) on wages, hours, benefits, roles, and workplace rules.

5. Regular Employment

Work performed must be on the basis of a recognized employment relationship established through local law and practice. Suppliers must not use labor-only contracting, apprenticeship schemes, temporary arrangements, or other practices to avoid obligations to workers.

Where contracts are used, workers must receive written agreements that are accurate, understandable, and do not restrict worker rights.

6. Benefits & Wage Deductions

All legally required benefits (including social insurance and paid leave where applicable) must be provided. Wage deductions must be lawful, transparent, and never used as a disciplinary measure.

Any deductions or withholdings must be clearly explained in advance, documented, and consented to where required by law.

7. Freedom of Association & Collective Bargaining

Workers are free to join, form, or participate in organizations of their choice (including trade unions) and to bargain collectively. Employers must recognize and respect these rights without penalty, discrimination, or interference.

8. Harassment, Abuse & Dignity

Every person shall be treated with dignity and respect. Physical, sexual, verbal, psychological, or any other form of harassment or abuse is strictly prohibited. No harsh or inhumane treatment, including unfair punishment, is allowed.

9. Health, Safety & Environment

Work environments must be safe and healthy, designed to prevent accidents or injuries related to work. Suppliers must provide appropriate safety training, safe equipment, and emergency preparedness.

Suppliers must manage environmental impacts responsibly, including waste, pollution, and resource usage, and comply with applicable environmental laws.

10. Working Hours & Rest

Working hours must comply with local laws. The regular workweek should not exceed 48 hours. Workers must receive at least 24 consecutive hours of rest every seven days.

Overtime must be voluntary, not required regularly, and compensated at premium rates. Except in exceptional circumstances, total hours (regular + overtime) shall not exceed 60 per week.

11. Nondiscrimination & Equal Opportunity

No discrimination in hiring, compensation, training, promotion, termination, or retirement based on gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group, or ethnic origin.

12. Women’s Rights & Equal Treatment

Female workers shall have the same opportunities and rights as male workers. Employment decisions may not be based on marital status, pregnancy, fertility status, or contraceptive use.

New mothers are entitled to leave for childbirth and recovery, and have the right to return to their position (or an equivalent position) as required by law.

Grievance, Reporting & Remedy

Suppliers and partners must maintain a safe, accessible process for workers to raise concerns without fear of retaliation. Workers must be able to report issues confidentially and receive timely responses.

When violations of this Code are identified, partners must cooperate in corrective action, remediation, and prevention of recurrence.

Reporting concerns: Report suspected violations to your supervisor or to office@sillytoast.com. Retaliation against good-faith reports is prohibited.

Implementation & Due Diligence

This Code is a living standard. FreedomWear Co. communicates expectations to partners, incorporates Code requirements into business relationships where practical, and works to verify and improve compliance over time.

For direct or owned factory / decorator relationships

When we own facilities or contract directly with manufacturers, factories, or decorators/embellishers, we expect Code standards to be implemented on-site, including worker access to the Code (posted and/or in orientation), periodic assessment of working conditions, and timely corrective action when issues arise.

For promotional products suppliers / indirect sourcing

When we source through intermediaries (wholesalers, promotional product suppliers, distributors, or similar), we expect partners to maintain their own compliance programs and to be transparent about how they communicate, monitor, and remediate workplace standards in their production networks. We may request documentation or commitments related to Code alignment and corrective actions.

We review this Code periodically and update it as expectations, risks, and regulations evolve.

Enforcement & Compliance

FreedomWear Co. may suspend or terminate any business relationship if these standards are violated or if a partner refuses to address verified non-compliance. All partners and suppliers must adopt and adhere to this Code as a condition of doing business with us.

We expect our partners to flow these standards down to their subcontractors and upstream supply chain where applicable.

From the President

Every employee and partner is responsible for understanding and adhering to this Code. By upholding these principles, we protect our people, our partners, and the communities we serve.

Greggory Payne
President, FreedomWear Co.
Date: February 18, 2026