New Balance Athletic Shoe, Inc.

Supplier Code of Conduct

Overtime

? Exceptional business circumstances requiring a workweek in excess of the local official workweek (or a 48-hour workweek, whichever is lower) shall be subject to the laws regarding the payment of overtime in addition to compensation for regular hours of work.

? In countries where there is no legal standard regarding overtime premiums, industry standards shall be the model. In no event shall this be at a rate less than the regular hourly rate.

? Factories shall carry out operations in ways that limit overtime to a level that complies with national labor laws and ensures productive and humane working conditions.

Freedom of Association

?  Employers shall respect the right of workers to join and organize associations of their own choosing, and to bargain collectively. Where local law limits the right of freedom of association, employers shall not obstruct legal alternative means of free association, and shall, in all cases, implement effective systems to assure open communication with employees.

Forced Labor

? There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor, or otherwise. There shall be no penalties or fines for declining overtime.

? Workers shall not be locked inside of factory premises for any reason.

Environmental Conditions

? All facilities shall comply with all local environmental laws. Manufacturers, subcontractors and suppliers must certify compliance with all applicable environmental regulations in their country.

Subcontractors

? This Code of Conduct applies to all subcontractors utilized by New Balance suppliers.

? All Suppliers are required to take all necessary steps to ensure that its subcontractors adhere to this Code of Conduct. No subcontractors will be used without New Balance’s prior approval.

In the event of any willful, non- compliance with the Code of Conduct, New Balance may terminate or refuse to renew our supply agreements with suppliers based on the suppliers’awareness of the Code of Conduct.