Supplier Code of Conduct

National Vision is committed to operating its business within a framework of principles, guidelines, and policies that are aligned with our ethical, social, and environmental responsibilities. We believe that this is critical for protecting, managing, and enhancing our brand and reputation. We also believe this will drive long-term, sustainable growth for National Vision, our business partners, and the communities in which we operate.

We strive to conduct business with suppliers who share our commitment to operating in a responsible and ethical manner. This Supplier Code of Conduct outlines our principles of responsible supplier management for ethics, labor, the environment, health and safety, and related management systems.

Laws and Regulations

Suppliers must comply with all applicable laws and regulations of the countries in which they operate.

Child Labor

Suppliers must not employ workers younger than the greater of (a) 15 years of age (or 14 where permitted by the local law consistent with International Labor Organization guidelines) or (b) the age for completing compulsory education or (c) the minimum age established by law in the country of manufacture. In addition, Suppliers must comply with all local legal requirements for the work of authorized young workers, particularly those pertaining to hours of work, wages, and working conditions.

Forced Labor

Suppliers must not use involuntary or forced labor, whether indentured, bonded, prison or otherwise.

Harassment

Suppliers must treat all workers with respect and dignity. No worker shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. In addition, Suppliers will not use monetary fines as a disciplinary practice.

Wage and Benefits

Suppliers must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to their compensation for regular hours of work, workers must be compensated for overtime hours at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly compensation rate.

Hours of Work

Suppliers must ensure that workers shall not be required to work more than the lesser of (a) sixty (60) hours per week or (b) the number of permitted regular and overtime hours allowed by the law of the country of manufacture. In addition, except in extraordinary business circumstances, all workers shall be entitled to at least one day off in every consecutive seven day period.

Health and Safety

Suppliers must provide their workers with a clean, safe and healthy work environment in compliance with all legal requirements for workplace health and safety in the countries in which they operate. This includes residential facilities, if applicable.

Nondiscrimination

Suppliers must ensure that the terms and conditions of employment – including hiring, remuneration, benefits, advancement, termination and retirement – are based on ability and not on criteria that are impermissible under local law.

Women’s Rights

Suppliers will ensure women workers receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment, and pregnancy testing – to the extent provided – will be voluntary. In addition, workers will not be forced to use contraception.

Freedom of Association and Collective Bargaining

Suppliers must recognize and respect the rights of workers to exercise lawful rights of free association, including joining or not joining any association. Suppliers must also respect any legal rights of workers to bargain collectively.

Subcontracting

All component suppliers must be sent a copy of this document. Finished products cannot be manufactured by a subcontracted factory that has not been sent this Supplier Code of Conduct.

Communication

Suppliers must communicate the provisions of the Code of Conduct to workers and supervisors.

Monitoring and Compliance

Suppliers must maintain on site all documentation necessary to demonstrate compliance with this Code of Conduct, and Suppliers must allow representatives of NVI full access to production facilities, worker records and workers for confidential interviews in connection with monitoring visits. Suppliers are expected to take necessary corrective actions to promptly remediate any noncompliance.

Preventing Bribery & Corruption

All corruption, bribery, extortion and embezzlement are prohibited. Suppliers do not offer, request or accept bribes or permit subcontractors or others to do so on their behalf. Suppliers will implement appropriate, ongoing anti-bribery and anti-corruption policies and training.

Preventing Conflicts of Interest

Suppliers do not allow personal or family interest to influence their independence or personal judgment. Suppliers have financial controls in place to prevent conflicts of interest affecting procurement and financial decision-making.

Competition

Suppliers only seek competitive advantage through lawful means and will conduct their business consistent with fair and vigorous competition and in compliance with all applicable anti-trust and competition laws.

Environment

Suppliers shall comply with all applicable regulatory requirements regarding the environment and health and safety, and shall operate an environmental, health and safety management system, which underpins and proves compliance with all such regulatory requirements. Suppliers shall operate in an environmentally responsible and efficient manner to minimize adverse impacts on the environment and demonstrate a culture of continual improvement to further reduce resource consumption.