Our Code outlines what we view as important in terms of Social Responsibility and it highlights some of the key standards that we expect of our Partners to meet or exceed. In addition to our review, we expect our Partners to have comprehensive and effective management systems and policies in place that enable them to monitor and measure their own compliance with our Code.

No person shall be employed at an age younger than 15 or younger than the age for completing compulsory education in the country of manufacture where such age is higher than 15.

All forms of forced, prison, compulsory or bonded labor, including prison labor, will not be tolerated by Stella & Dot. Partners shall maintain employment on a voluntary basis. Stella & Dot will not accept products from Partners who utilize in any manner forced labor in the manufacture or in their contracting, subcontracting or other relationships for the manufacture of their products.

Partners will provide a work environment free of harassment, abuse or corporal punishment in any form. Partners may not deny workers their rights and dignity. Corporal punishment and physical coercion must not be used. Partners must not engage in or tolerate sexual harassment, indecent or threatening gestures, abusive tone or language and undesired physical contact.

Stella & Dot recognizes that cultural differences exist and different standards apply in various countries; however, we believe that all terms and conditions of employment should be based on an individual's ability to do the job, not on the basis of personal characteristics or beliefs. Stella & Dot expects Partners to have a social and political commitment not to discriminate against their employees in hiring practices or any other term or condition of work, on the basis of race, color, national origin, gender, religion, disability, or other similar factors.

Partners must respect the rights of employees to exercise their lawful rights of free association and collective bargaining, and to join or not join the organization of their choice, without penalty or interference. In countries where freedom of association is prohibited, decided by the State, or limited (i.e. free trade zones), Partners should facilitate parallel means of independent and free association and bargaining for all workers. Workers' representatives shall not be the subject of discrimination and shall have access to all workplaces necessary to carry out their representation functions.

All Partners will ensure that workers who are women receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment or continuation thereof and pregnancy testing, to the extent it is provided, will be voluntary and at the option of the worker. Workers will not be exposed to hazards that may endanger their reproductive health and Business Partners will not force workers to use contraception.

Partners shall maintain reasonable employee work hours in compliance with local standards and applicable national laws of the countries in which the Partners are doing business. In any event, except in extraordinary business circumstances, employees will not work in excess of 60 hours per week, including overtime. Workers shall be provided with at least one day off for every 7 day period. Overtime shall be voluntary. We will not use Partners who, on a regularly scheduled basis, require employees to work in excess of the statutory requirements without proper compensation as required by applicable law. Employees should be permitted reasonable days off, breaks, lunch periods, and bathroom breaks.

Partners shall fairly compensate their employees by providing wages and benefits, which are in compliance with the national laws of the countries in which they are doing business or which are consistent with the prevailing local standards in the countries in which they are doing business, if the prevailing local standards are higher. Deductions from wages as a disciplinary measure shall not be permitted. Partners shall only use subcontractors who comply with this standard, if applicable.

Stella & Dot maintains a safe, clean, healthy and productive environment for its employees and expects the same from its Partners. Partners shall furnish employees with safe and healthy working conditions. Partners working on Stella & Dot merchandise shall provide adequate medical facilities, fire exits and safety equipment, well-­‐lighted and comfortable workstations, clean restrooms, and adequate living quarters where necessary. Workers should be adequately trained to perform their jobs safely.

Stella & Dot will favor Partners who take a progressive approach to minimize negative impacts on the environment. Partners shall have written environmental policies and standards and must comply with environmental laws, regulations and standards applicable to their industry. Stella & Dot encourages our Partners to reduce excess packaging and to use recycled and non-­‐toxic materials whenever possible.

Partners that wish to outsource or subcontract work on Stella & Dot products must obtain prior authorization for outsourcing or subcontracting from Stella & Dot. Complete information about the subcontractor should be provided in a timely manner. Subcontractors are expected to comply with the Stella & Dot Standards.

Homeworking is an important aspect of the world economy. In developing countries as many as 300 million people, more than half of them women, do paid work at home, making a significant contribution to household incomes among predominantly poor families. The lack of visibility of homeworkers in supply chains, combined with their complicated employment status in many countries, has made them a vulnerable group of workers. We believe that one of the first steps towards reducing the vulnerability of these workers is to take an open and positive position towards homeworking. By reacting negatively to instances of homeworkers in our supply chain, there is a danger of sending homeworkers underground and thus preventing any progress on improving their labor conditions, or unintentionally causing workers to lose their sole means of income. Therefore Stella & Dot does allow for the employment of Homeworkers if the Partner obtains authorization from Stella & Dot and agrees to abide by our Homework Guidelines and requirements.

Stella & Dot is committed to working with Partners who are open and honest with us. Stella & Dot Partners shall maintain complete and accurate records and information so that compliance can be effectively assessed. Partners must not falsify or understate any aspects of their operations to Stella & Dot or our representatives. Partners must not coach employees on how to answer questions or respond to inquiries by Stella & Dot or our representatives.

Stella & Dot will undertake affirmative measures such as unannounced on-­‐site inspections of Partner premises and production facilities, to monitor compliance with this Code of Conduct. Partners must maintain on site all documentation necessary to demonstrate compliance with this Code of Conduct. Partners must allow Stella & Dot associates and/or its third party monitoring firm’s full access to premises and production facilities, worker records and workers for confidential interviews in connection with monitoring visits.

Version 3, Dated September 15, 2012