ELIZABETH ARDEN, INC. GLOBAL SUPPLIER COMPLIANCE PRINCIPLES

These Global Supplier Compliance Principles apply to all facilities that produce goods or supply materials or components for Elizabeth Arden, Inc. or any of its subsidiaries, divisions, or affiliates, including facilities owned and operated by Elizabeth Arden's contractors, agents and suppliers herein referred to as "Elizabeth Arden Authorized Facilities."

While Elizabeth Arden recognizes that there are different legal and cultural environments in which production facilities operate throughout the world, these Global Supplier Compliance Principles set forth the basic requirements all production facilities must meet in order to do business with Elizabeth Arden.

Elizabeth Arden strongly encourages its contractors and suppliers to exceed these Global Supplier Compliance Principles and promote best practices and continuous improvement throughout all of their facilities. These Global Supplier Compliance Principles or their equivalent must be posted in all major workplaces and translated into the language(s) of the local employees.

Principle 1 - Legal and Ethical Business Practices: All Elizabeth Arden Authorized Facilities must fully comply with all applicable laws of the countries in which they are located including all laws, regulations and rules relating to wages, hours, employment, labor, health and safety, the environment, immigration and the manufacturing of fragrance, skin care and cosmetic products, and all applicable anti-corruption laws, including, but not limited to, the United States Foreign Corrupt Practices Act and the UK Anti-Bribery Act. Employers must be ethical in their business practices and must not engage in any form of bribery, corruption, extortion or otherwise seek to unjustly influence the official or business decisions of private individuals (including customer or vendor employees), public officials and/or the judiciary.

Principle 2 - Child Labor: No person shall be employed at an age younger than (i) 15 (or 14 where consistent with International Labor Organization guidelines) or (ii) the age for completing compulsory education in the country of manufacture where such age is higher than 15. All Elizabeth Arden Authorized Facilities must observe all legal requirements for work of employees under 18 years of age, particularly those pertaining to hours of work and working conditions.

Principle 3 - Forced Labor: Elizabeth Arden Authorized Facilities will not use, participate in or benefit from involuntary or forced labor - indentured, bonded or otherwise - or human trafficking of any kind.

Principle 4 - Wages and Benefits: Elizabeth Arden recognizes that compensation packages vary by locale. All Elizabeth Arden Authorized Facilities must compensate their employees fairly by providing compensation packages comprising wages and benefits that, at the very least, comply with legally mandated minimum standards of the prevailing industry wage and must provide legally mandated benefits. Employees must be fully compensated for overtime according to local law and each employee must be provided with a clear, written accounting for each pay period.

Principle 5 - Hours of Work: Elizabeth Arden Authorized Facilities must ensure employees' hours worked shall not exceed the legal limitations on regular and overtime hours in the jurisdiction in which they operate. Employees must be informed at the time of hiring if mandatory overtime is a condition of employment.

Principle 6 - Freedom of Association and Collective Bargaining: Elizabeth Arden Authorized Facilities shall obtain and comply with applicable local and national laws and regulations regarding freedom of association and employee rights to form and join trade unions and bargain collectively. No employee shall be subject to harassment, intimidation or retaliation in their efforts to freely associate or bargain collectively.

Principle 7 - Health and Safety: Elizabeth Arden Authorized Facilities must provide their employees with a clean, safe and healthy work environment, designed to prevent accidents and injury to health arising out of or occurring during the course of work. All Elizabeth Arden Authorized Facilities are required to comply with all applicable, legally mandated standards for workplace health and safety in the countries and communities in which they operate.

Principle 8 - Nondiscrimination: While Elizabeth Arden recognizes and respects cultural differences, employment - including hiring, remuneration, benefits, advancement, termination and retirement - should be based on ability and not on belief or any other personal characteristics. Elizabeth Arden Authorized Facilities may not discriminate on the basis of race, age, color, national origin, gender, religion, sexual orientation, disability, political opinion, or social or ethnic origin.

Principle 9 - Harassment: All Elizabeth Arden Authorized Facilities must treat all employees with respect and dignity. Elizabeth Arden Authorized Facilities may not subject employees to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. In addition, Elizabeth Arden Facilities may not use monetary fines as a disciplinary practice.

Principle 10 - Women's Rights: Elizabeth Arden Authorized Facilities must ensure that women workers receive equal remuneration, including benefits; equal treatment; equal evaluation of the quality of their work; and equal opportunity to fill all positions open to male workers. Pregnancy tests will be not be a condition of employment, nor will they be demanded of employees. Workers who take maternity leave (of a duration determined by local and national laws) will not face dismissal nor threat of dismissal, loss of seniority or deduction of wages, and will be able to return to their former employment at the same rate of pay and benefits. Workers will not be forced or pressured to use contraception. All required safety precautions should be taken to prevent workers from being exposed to hazards and/or hazardous materials that may endanger their health or safety, including their reproductive health. Facilities shall provide appropriate services and accommodation to women workers in connection with pregnancy.

Principle 11 - Subcontracting: Elizabeth Arden Authorized Facilities will not utilize subcontractors in the manufacturing of Elizabeth Arden products or components without Elizabeth Arden's written approval and only after the subcontractor has agreed to comply with these Global Supplier Compliance Principles.

Principle 12 - Monitoring and Compliance: Elizabeth Arden Authorized Facilities will maintain readily available all documentation necessary to demonstrate compliance with these Global Supplier Compliance Principles. Elizabeth Arden and its subsidiaries may undertake affirmative measures, such as announced and unannounced on-site inspections, by Elizabeth Arden personnel or third-party auditors designated by Elizabeth Arden, of production facilities, to monitor compliance with these Global Supplier Compliance Principles. Elizabeth Arden Authorized Facilities must allow Elizabeth Arden representatives full access to their facilities, employee records and employees for confidential interviews in connection with monitoring visits. In addition, Elizabeth Arden Authorized Facilities must respond promptly to reasonable inquiries by Elizabeth Arden representatives concerning the subjects address in the audit.

Principle 13 - Informed Workplace: Elizabeth Arden Authorized Facilities should inform employees about the workplace standards orally and through the posting of standards in a prominent place and undertake other efforts to educate employees about the standards on a regular basis.

Principle 14 - Facility Security: It is Elizabeth Arden's policy that all Elizabeth Arden Authorized Facilities establish facility security procedures to guard against the introduction of non-manifested cargo into outbound shipments. Such items would include drugs, biological agents, explosives, weapons, radioactive materials, other contraband, and illegal immigrants.

Principle 15 - Environment: Elizabeth Arden Authorized Facilities must comply with all laws and regulations relating to environmental protection in the countries in which they operate. Elizabeth Arden Authorized Facilities should have policies and procedures in place to ensure environmental impacts are minimized with respect to energy, air emissions, water, waste, hazardous materials and other significant environmental risks. Elizabeth Arden Authorized Facilities are expected to make sustainable improvements in environmental performance and require the same of their suppliers and sub-contractors.

Principle 16 - Suppliers: Elizabeth Arden Authorized Facilities will take responsibility to require adherence to the principles of these Global Supplier Compliance Principles from their respective direct suppliers and exercise diligence in verifying that these principles are being adhered to in their supply chains. We recognize that many of the issues facing manufacturers like Elizabeth Arden may arise in the further tiers of extended supply chains where many more suppliers are involved. It is therefore essential that Elizabeth Arden Authorized Facilities recognize the role they have to play in promoting responsible sourcing practices with their own suppliers and in ensuring the principles are cascaded and compliance monitoring takes place.

Violations of these Global Supplier Compliance Principles will be appropriately remedied at the cost of the Elizabeth Arden Authorized Facility. Elizabeth Arden reserves the right to take necessary measures to ensure future compliance with these Global Supplier Compliance Principles. Failure to comply with these Global Supplier Compliance Principles will be considered a material breach of the applicable legal agreement or framework and may ultimately result in termination of the relationship between Elizabeth Arden and the Elizabeth Arden Authorized Facility.



Rev. January 2015