Supplier Code of Conduct

Pen Company of America (“PCA”) is committed to conducting its business in an ethical, legal, and socially responsible manner, particularly the avoidance of forced labor. PCA expects its suppliers to share this commitment and, therefore, has established this Supplier Code of Conduct. Although there may be different legal and cultural environments applicable to its suppliers, PCA suppliers must meet the following minimum requirements in order to do business with PCA:

1. Compliance with Laws, Regulations, and Published Standards
PCA suppliers must comply with all applicable laws, codes, or regulations of the countries, states, and localities in which they operate. This includes, but is not limited to, laws and regulations relating to environmental, occupational health and safety, and labor practices. In addition, PCA suppliers must require their suppliers (including temporary labor agencies) to do the same. PCA suppliers must conform their practices to any published standards for their industry.

2. Environmental Practices
PCA suppliers shall comply with all environmental laws and regulations applicable to their operations worldwide. Such compliance shall include, among other things, the following items:

(a) Obtaining and maintaining environmental permits and timely filing of required reports;

(b) Proper handling and disposition of hazardous materials;

(c) Monitoring, controlling, and treating discharges generated from operations.

3. Occupational Health and Safety Practices
PCA suppliers shall provide their employees with a safe and healthy working environment in order to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of the supplier. Suppliers shall, among other things, provide

(a) Occupational health and safety training;

(b) A system for injury and illness reporting;

c) Medical treatment and/or compensation to injured/ill workers arising as a result of working for supplier;

(d) Machine safeguarding and other protective measures to prevent injuries/illnesses to workers;

(e) Clean and safe facilities.