1.0 Scope

FOX Corporation is committed to conducting business as sustainably and responsibly as possible, both in our direct actions and in our impacts through our suppliers, licensees, affiliates, and partners.

FOX asks that employees, suppliers, licensees, affiliates, and partners use this Supplier Management Policy as a guiding principle in the procurement, production and distribution of any FOX-branded products or services.

2.0 Definitions

Forest Stewardship Council (FSC) – FSC is an independent, non-profit organization that sets standards under which forests and companies are certified. FSC was founded in 1993 to promote responsible forest management.

Supply Chain Sustainability – the management of environmental, social and economic impacts, and the encouragement of good governance practices, throughout the lifecycles of goods and services.

Responsibly Managed Forests – Forests that are operating legally, protecting biodiversity and not causing tropical deforestation or conversion of natural tropical forests to plantations.

3.0 Roles and Responsibilities

3.1 Department Heads and Supervisory Personnel

Department Heads and Supervisors will:

1. Ensure that all personnel are informed of the contents of this policy.
2. Support the use of responsible suppliers, licensees and affiliates.

3.2 Employees

All employees who purchase on behalf of FOX will:

1. Observe the Supplier Management requirements for their Department.
2. Refrain from using suppliers who do not conduct business in a socially responsible manner or who are operating illegally.

3.3 Accounting Department

Accounting personnel will:

1. Work with the appropriate Department Head and FOX EHS Department to track all sustainable purchases such as, but not limited to, FSC certified lumber, plywood and/or meranti-alternatives such as Revolution Ply.

3.4 Environmental, Health and Safety Department

The Environmental, Health and Safety (EHS) Department will:

1. Develop and maintain appropriate standards for suppliers, licensees, affiliates, and partners activities.
2. Provide technical assistance and vendor recommendations in the use of suppliers.
3. Periodically review, revise and update this Procedure, as necessary.
4. Periodically review employees, suppliers, licensees, affiliates, and partners

4.0 Procedures

4.1 Supplier, Licensee, Affiliate, and Partner Resource Use

FOX is committed to working with its suppliers, licensees, affiliates, and partners to ensure that their use of resources is sustainable. It is our goal to review their sustainability policies and encourage them to engage in conservation and efficiency measures for their water and energy use, to increase the utilization of renewable energy sources, and to minimize waste.

We expect all our suppliers, licensees, affiliates, partners, and their third-party manufacturers to use clean manufacturing processes in the creation of FOX-branded products. We select supply partners who practice clean manufacturing and demonstrate a commitment to continuous improvement in pollution prevention and source reduction that meets or exceeds legal requirements, so as to minimize the environmental impact of their operations on our air, water and climate.

Our suppliers are expected to:

• Comply with all applicable federal, state and local laws, regulations and permits.
• Measure and reduce their GHG emissions.
• Strive to reduce their environmental impact on an ongoing basis.
• Reduce their use of energy in the operation of their business where possible.
• Use alternative renewable energy sources where practical.
• Demonstrate that they have an active recycling program
• Commit to using recycled-content products where practical as part of their materials-sourcing practice.
• Maximize their use of recycled fiber where practical and possible.
• Use only legally sourced and, where possible, certified raw materials in their operations.
• Subscribe to and participate in credible chain-of-custody certification programs for renewable resources.
• Certify that their programs are or can be third-party audited, and that such audits are conducted regularly with senior management signoff.
• In the case of paper suppliers, ensure all paper is elemental chlorine free, and this must be documentable.
• Have an active, ongoing training program in which their employees are encouraged to participate.

4.2 Environmental Management System

Our suppliers are encouraged to have a documented environmental policy that includes a commitment to comply with relevant environmental legislation and regulations and to continual improvement and pollution prevention.

A system should be in place to minimize the use, disposal and emissions of hazardous chemicals.

An on-going emphasis should be placed on materials that are compliant with applicable regulations like WEEE, biodegradable, recyclable, reusable and/or reduces pollutant emissions at the point of use.

4.3 Product and Employee Safety

Our suppliers must comply with all applicable local laws and regulations for product and employee safety in the countries where they operate. Our U.S. suppliers must comply with all regulations of the Consumer Product Safety Commission (CPSC) and the Occupational Safety and Health Act (OSHA). The materials they use, including adhesives, pigments, inks, coatiFox, solvents, substrates, curing processes and packaging, must meet the standards for toxicity established by the CPSC or the lowest threshold established by any of the 50 states, whichever is stricter.

All our suppliers are expected to:

• Safeguard their employees from exposure to toxic materials and injury, and provide safe working conditions.
• Conduct their business with an emphasis on reducing industrial accidents.
• Use non-toxic cleaning supplies wherever possible, as well as non-toxic printing and binding materials.
• Be open, transparent and fair. Minimize waste, maximize the use of renewable energy, reduce the carbon emissions of their operations and promote these values among their employees.
• Comply with all applicable local laws and regulations in the jurisdictions in which they operate.

4.4 Materials

Our goal is to source and use only materials that are certified to be legally secured, sustainably harvested or manufactured, made without use of illegal or forced labor, and traded freely on the open market. We especially look for materials that are sustainably made, manufactured using renewable materials and renewable energy, are recyclable and have the lowest environmental impact.

4.4.1 The Lacey Act

The Lacey Act makes it illegal to import illegally sourced plants or animals (forest products included) into the United States, and makes it illegal to import products made from illegally sourced plants or animals. Fox requires its suppliers to abide by all the requirements and conditions of the Lacey Act.

4.4.2 Paper and Packaging

It is FOX’s practice to recycle paper as much as possible and, where possible and practical, to make new products from recovered fiber. FOX supports the growth of forest certification worldwide while protecting the rights of indigenous people and ensuring the protection and preservation of unique stands. Fox also strives to buy only certified paper products.

We work with our suppliers to implement the philosophy of reduce, reuse and recycle in developing packaging for the products that we source. Our goal is to make packaging materials and products from recycled fiber where possible, to minimize the amount of packaging, to make that packaging as recyclable as possible (minimizing or eliminating non-recyclable components) and to actively encourage the recycling of the package.

4.5 Audit and Inspections

FOX has the continuing right to periodically inspect Suppliers, Licensee’s and/or any Third-Party Manufacturer’s facilities.  Advance notice need not always be provided prior to such inspection, so as to preserve the integrity of the inspection process.

4.6 Compliance

Violation of this policy may, in FOX’s sole discretion, result in the termination of our business relationship with a Licensee, Affiliate, Partner, or Supplier.

5.0 REFERENCES

Lacey Act

Resource Efficiency and Cleaner Production

United Nations Environmental Program

Programme for the Endorsement of Forest Certification (PEFC)

Forest Stewardship Council (FSC)

Sustainable Forestry Initiative (SFI)

American Tree Farm System (ATFS)

Canadian Standards Association (CSA)

Rio Declaration on Environment and Development