Ethics and the environment have always been important issues for the New Wave Group, and the Group closely monitors how suppliers treat their employees as well as issues relating to the environment.Social Code of Conduct

The New Wave Group has a responsibility to ensure that its own operations and those of its suppliers respect the legal requirements in various countries as well as international organisations� views of basic rights. The Group�s Code of Conduct is applied to all factories that are involved in the production of the New Wave Group�s products. While the Group is aware of the different legal and cultural conditions under which factories operate all around the world, this Code of Conduct defines basic requirements that all factories must comply with in order to do business with the New Wave Group.

The Code of Conduct is an agreement that the Group�s suppliers commit to observing, and prescribes, among other things, that the supplier must comply with legal requirements and provide the Group with full access to factories and data for evaluation of the supplier�s compliance with the rules. The Code of Conduct further includes, inter alia, bans on child labour and discrimination, requirements for basic working conditions, the right to freely organize trade unions, payment of minimum wage and overtime pay, and limits on hours of work. Since 2008, the New Wave Group has been a member of the Fair Labor Association (FLA, see www.fairlabor. org) which is an international organisation that works to improve the social situation and working conditions in production countries and is a model for the future. The FLA�s code of conduct, to which the New Wave Group has conformed its code, provides the same customer requirements to all suppliers, thus making it easier to implement requirements, to institute training, to conduct evaluation and audits, and for the supplier to comply.

Direct trade
The New Wave Group�s purchasing strategy is based on purchasing directly from manufacturers via the Group�s own purchasing offices. Quality controllers and Code of Conduct staff from the Group are on site at the factory, which is a prerequisite for the creation of an effective management system for environmental work and the Code of Conduct. Although the basic requirement of a supplier is total access and transparency, this is sometimes difficult to achieve because there are so many different stages in the production chain. However, the New Wave Group�s substantial local presence gives the Group good control over all aspects of production, particularly social responsibility.

Code of Conduct organisation
The Group�s Code of Conduct organisation is led from our head purchasing office in Shanghai, and currently employs a total of nine people working full time among the 4 liaison offices. The Group also has over 30 trained quality controllers throughout Asia who conduct �visual inspections� at the factories, in some cases daily. In total the New Wave Group conducts over 300 full inspections and more than 1,500 visual inspections each year.

Continuous improvements
The Group�s supplier strategy is to create longterm relationships while maintaining a minimal number of key suppliers, thus enabling the Group�s recognition as a large and important customer and the benefits that come with such distinction. As part of its strategy, the New Wave Group strives to work with its suppliers to improve and develop within the Code of Conduct requirements. To this end, the Group uses announced and unannounced inspections by COC staff, regular visual checks by quality controllers, independent audits by FLA, as well as training seminars by local NGOs. Such constant evaluations and training provide the New Wave Group with the ability to identify potential pitfalls before they happen. Even in the instances when faults are identified, the Group�s strategy allows it to isolate the issue and develop a remediation plan to bring the supplier back to an acceptable position within a reasonable timeframe�usually 1-3 months--rather than immediately terminating a supplier. Through such means, the New Wave Group can achieve the highest possible compliance of the Group�s strict minimum requirements while at the same time making significant social advancements in the production countries.

The environment
The New Wave Group recognizes how closely connected its business activities are to local and global environmental issues. To this end, the Group is actively engaged in �green management,� an effort to reduce environmental threats through implementation of business plans that incorporate environmental considerations. Specifically, the New Wave Group is developing plans for Transportation, Eco-friendly offices, Packaging, Chemical use, and �Green� production.

Transportation & Logistics: Developing and using the cleanest and most efficient transport operations is a significant concern to the New Wave Group. The Group works with some of the largest transportation companies in the market, all of which have environmental programmes in place for their operations. An evaluation of these programmes is an important element of the procurement process for freight services. In order to reduce the impact on the environment, the Group consolidates as much as possible of its Asian transport operations between the various companies. In addition, the New Wave Group has joined �Clean Shipping,� an attempt to pressure shipping companies to use cleaner vessels. The Group also strives to minimize its use of air transport, a source of great impact on the environment, for only the most essential needs.

Eco-friendly offices: All companies in the New Wave Group strive to reduce their consumption of water, electricity and paper, to eliminate waste, and to ensure hazardous materials are disposed of properly.

Packaging: Production units are using recycled materials such as plastic bags and cardboard cartons for shipping product as well as reducing and eliminating unnecessary packing material.

Chemical use: Quality control visual inspections allow the New Wave Group to maintain strict control over the chemical substances used in and for its products. The Group is committed to taking steps to reduce, substitute and eliminate chemical substances that are harmful to the environment.

Green production: The New Wave Group is developing sustainable products using new materials such as organic cotton and recycled fabric. The Group also imposes strict requirements on its suppliers to use humane treatment on animals including but not limited to certification against plucking feathers from live birds.

In addition to developing environmental business plans, the Group strives to achieve environmental awareness through close collaboration with suppliers. The Group�s Code of Conduct defines requirements for environmental issues including but not limited to water treatment, waste management and chemical handling. Suppliers must also comply with the chemical restrictions defined in the chemicals guide issued by the Textile Importers Association in Sweden, as well as the prevailing rules in the EU and the USA in respect of such matters as the use of virgin raw materials, emissions of �unnatural� material, waste, emissions to air, energy consumption and consumption of fresh water. Further, products are tested regularly in the Group�s own laboratories in Asia or at independent testing institutes in order to guarantee that suppliers are complying with the company�s rules and restrictions. The total of these efforts represent a framework for the Group�s global activities to minimize the company�s environmental impact