Payton is committed to upholding the human rights of our workers and will treat them with dignity and respect as understood by the international community. Payton recognizes that the quality of products and services, consistency of production, and worker’ morale are enhanced by promoting safe and healthy work environment standards. Payton will comply with all applicable environmental laws, regulations and standards and recognizes the adverse effects on the environment when conducting business. Payton has established a management system whose scope is related to the content of this Code. The management system is designed to ensure: (a) compliance with applicable laws, regulations, and customer requirements related to Payton’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code.
Such standards are outlined as follows:

1. Labor

a. Forced, bonded, or indentured labor or involuntary prison labor will not be used. All work must be voluntary and workers should be free to leave upon reasonable notice.

b. Child labor will not be used at any stage of manufacturing. The term “child” refers to any person employed under the age of 16, under the age for completing compulsory education or under the minimum age for employment in the country, which ever is greatest.The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported.

c. Payton is committed to a workforce free of harassment and unlawful discrimination. Payton shall not engage in discrimination based on race, color, age, gender, sexual orientation,ethnicity, disability, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, reward sand access to training

d. There should be no harsh and in humane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse of workers or threats of any such treatment.

e. Compensation paid to workers should comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Any disciplinary wage deductions are to conform to local law.

f. Work weeks, including overtime, are not to exceed the maximum set by local law.

g. Payton respects the rights of workers to associate freely, in accordance with local laws. Workers are able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.

2. Health &Safety

a. Physical guards, interlocks and barriers will be provided and properly maintained for machinery used by workers.

b. Worker exposure to chemical, biological and physical agents is to be identified, evaluated and controlled. When hazards cannot be adequately controlled by engineering and administrative means, workers are to be provided with appropriate protective equipment.

c. Worker exposure to workplace safety hazards (e.g. electrical, fire and vehicle hazards) is to be controlled through proper design, engineering,administrative controls and preventative maintenance procedures.

d. Emergency situations and events are to be identified and assessed and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, worker notification and evacuation procedures, worker training, appropriate fire detection and suppression equipment, adequate, exit facilities, and recovery plans.

e. Procedures and systems are to be in place to manage, track, and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.

f. Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks are to be identified, evaluated, and controlled.

g. Workers are to be provided clean toilet facilities and access to potable water and sanitary food preparation and storage facilities.

3.Environment

The minimum standards to protect the environment are outlined as follows:

a. Chemicals, air emissions and other hazardous materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling,movement, storage, recycling or reuse and disposal.

b. Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities are to be monitored, controlled, and treated as required prior to discharge or disposal.

c. Reducing resources,such as energy and water and reducing or eliminating pollutions at the source,or by practices such as modifying production or modifying facility processes,materials substitution, conservation and recycling.

d. All required environmental permits and registrations are to be obtained and kept current and their operational and reporting requirements are to be followed

4.Business Ethical

a. Embracing the concept of corporate social responsibility and fostering positive relationships with the local community.

b. Avoiding relations with criminal groups or gangs and prohibiting any form of corruption,extortion, and embezzlement in all business transactions. Bribes or other means of obtaining an improper advantage are not to be offered or accepted. Payton employees shall not offer or accept gifts of any kind if they influence improperly or create the appearance of improper influence on business decisions.

c. Upholding fair business, advertising, and competition standards.

d. Respecting legitimate intellectual property rights of third parties and will not intentionally infringe on or make unauthorized use of any such rights

e. Disclosing information concerning the operation, status of business activities and other corporate information in an appropriate manner and in compliance with applicable laws and regulations.

5.Management system

a. Information regarding business activities, structure, financial situation and performance is to be treated in accordance with applicable laws, regulations and prevailing industry practices.

b. An anonymous reporting system in place for employees to report violations. Such system ensures the protection of employee whistle blower confidentiality.

c. A system to identify assumed risks associated with Payton’s operations. The relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks should be determined.

d. Training for managers and workers on company programs, policies, procedures, and improvement objectives.

e. Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of this Code and customer contractual requirements should be conducted.

f. Process for timely correction of deficiencies,identified by internal or external assessments, inspections, investigations and reviews should be managed.

Green House Gases

Global warming has become such an issue that if people do not become aware and take action there could be serious consequences. Payton will implement the following greenhouse gas (GHG) emission management scheme to meet the challenges of global warming:

Implement yearly education about global warming and greenhouse gas (GHG) emission control to public and also internally.

Implement yearly greenhouse gas (GHG) emission checks internally to identify chance to reduce greenhouse gas (GHG) emission.

Implement relative energy saving techniques to reduce direct or indirect impact to environment and green house effects.

HSPM & Conflict Metals

In order to ensure the environment-related substance of product can conform to international laws, regulations and customer's requirements reduce the environmental impacts on product, enhance the capability of product competition. Payton have already built up the Hazardous Substance Process Management System (HSPM).

1. Implement overall education about hazardous substance process management.

2. Establish HSF policies and objectives evidencing PTN's commitment to HSF conformity.

3. Establish and implement HSF supply chain and HSF material process management system for ensuring materials compliance to PTN's HSF requirements.

4. Establish and implement HSF manufacturing and HSF quality assurance process management system for ensuring products compliance to customer's HSF requirements.

The labor union organizes related staffs to visit sick employees.

· Company holds the dormitory leaders meeting quarterly to communicate with employees for accommodation problems and provide the solution.

· Company organize many kinds of activities in order to let employees feel relax and make fun for their off time.

· Company organizes annual outing, dinner and other team building activities.

· Company provides body checks and focus on the employees’ health.

· Company provides trainings to employees and helps them to develop their work skills.