Bluewater’s Child Labor Policy Bluewater has a child labor policy that defines our position on employing minors and aims to ensure that our company, its subsidiaries and everyone we’re connected with follows the law and cares for the interests of children. Millions of children are still forced to work in bad conditions all around the world, even in developed countries. As an organization, at Bluewater we want to do business in a legal, ethical manner that adds value to society and the environment. Helping stop child labor is fundamental to us. For that reason weseek to do all we can to make sure that our organization doesn’t take part in children’s exploitation and also helps end it to the best of our ability. This policy applies to the entire Bluewater organization and those we do business or partner with including suppliers, vendors and contractors. The International Labour Organization (ILO) and the U.N Convention on the Rights of the Child guide our policy on child labor. When it comes to legal aspects, we always: Follow the stricter law if more than one laws apply (e.g. state and federal, local and international). Require suppliers, partners and vendors to follow the stricter applicable laws and recognize children’s rights. They must also require their own suppliers, subcontractors and stakeholders to do the same. In this policy, we refer to “children” as people who are younger than 16 years of age. “Young children” are people younger than 14. “Child labor” refers to work that deprives children of their childhood and affects their schooling, their potential and their dignity. It’s work that’s harmful to them mentally, physically and socially. POLICY ELEMENTS YOUNG CHILDREN When it comes to young children (younger than 14), we don’t and won’t employ anyone younger than 15 of age and require our subsidiaries to do the same, regardless of the country they’re in. We’re also committed not to do business with any organization that employs children younger than 15. Our aim is to include this condition in every contract we sign and reserve the right to break the contract without penalty if our stakeholder violates this condition and refuses to agree on or follow through with an elimination plan. LEGAL EXCEPTIONS Parental employment. We might occasionally do business with family-owned businesses. Those businesses are usually allowed to employ the owner’s young children as long as the work isn’t hazardous. We accept this regulation, but we’ll still dissolve our contract if it comes to our attention that these children are exposed in danger or are working consistently during school hours. Occasional work. Sometimes, parents bring their children to work to teach them skills and introduce them to a work environment. They may also hand them some tasks to complete (e.g. a painter may ask his child to help with a painting job he’s taken). This is an acceptable practice, as long as it doesn’t deprive children of school on a consistent basis or puts them in any danger. (For example, the painter shouldn’t allow his son to inhale toxic paint or ask him to climb on scaffolding.) OLDER CHILDREN When it comes to employing children who are older than 16, we strive to always follow the local and international laws. As a general rule, these children can have a job, but they should never do work that jeopardizes their health and safety or affects their schooling and development. With this rule in mind, we or or suppliers may employ children older than 16 for light work that does not involveusing any heavy or dangerous equipment, chemicals or vehicles when working. We also strive to determine their work hours and wage are based on applicable laws and we do not accept the employment of children for more than the applicable maximum national weekly or daily hours allowed. These are mandatory conditions for Bluewater when forming partnerships or other business relationships. We’ll refuse to do business with anyone who employs children of any age in hazardous or exhausting jobs or doesn’t follow applicable laws on working hours or pay. We also expect them to communicate and enforce the no child labor policy to their own contractors. ACTIONS AND IMPLEMENTATION To make sure we enforce this policy and help eliminate child labor, we’re committed to: Working with governments and other organizations to end child labor. We may sponsor or organize actions to educate communities, build schools or find ways to ensure children won’t be forced to work to support their families. Educating our staff on youth work laws and show them how to report child labor if they see or suspect it. Requiring hiring managers and HR to avoid hiring minors under the legal age for working. We also expect them to know and follow this policy and laws on wages and hours for older children. Keeping and validating documentation verifying our employees’age after they’re hired. If we discover that we’ve hired a minor under the age of 18, we’ll review applicable laws and adjust working hours accordingly. If we need to let the child go, we’ll assess their situation and make sure to provide for them to the best of our ability (e.g. pay him or her their would-be salary for a couple of months) when necessary. Communicating our no child labor policy to organizations we’re connected with and ensure our contracts have the right stipulations. Auditing suppliers and partners periodically to ensure they aren’t involved in child labor, possibly with unannounced onsite visits too. We’ll require them to provide us with an updated list of all their business locations at all times. If we discover hidden business sites that employ children, we’ll dissolve our contract immediately. Demanding and monitoring an elimination plan in cases where suppliers discover child labor in their business. We’ll also work together with the stakeholder to create plans to support children, keeping their best interests in mind, and make efforts to involve them and their families in the process. Employing or consulting with experts on topics like child labor, health and safety standards or corporate social responsibility. CHILDREN’S WELFARE IS EVERYONE’S BUSINESS At Bluewater we want to grow and thrive as a business, but we’re also committed to do good by the community we belong in. We ask all of our employees and partners to follow our child labour policy, not just because we demand it as an organization, but because securing a bright future for children is everyone’s duty.