RTM English

Ready To Manufacture

VERSION 2.0

INDEX

Index Introduction

1

Scope

1

Objective

1

RTM Description

1

Key Definitions

3

A. Goo ood d Ma Manu nufa fact ctur urin ing g Pr Prac acti tice ces s an and d Be Best st Pr Prac acti tice ces s fo forr IN INDI DITE TEX X Di Dire rect ct Su Supp ppli lier ers s and Su Subb-Su Supp ppli lier ers s6 1. INDITEX Direct Supplier and Sub-Supplier Staff

7

1.1. INDITEX Product Health and Safety Standard Compliance Manager

7

1. 2. Training Training of the INDITEX Product Health and Safety Standard Compliance Manager

8

2. Traceability Documents

9

2.1. Purchase Orders to Suppliers

9

2.2. Documentation and Records

9

B. Good Manufacturing Practices and Best Practices for Mills

11

1. Mill Staff

12

1.1. INDITEX Product Health and Safety Standard Compliance Manager

12

1. 2. Training Training of the INDITEX Product Health and Safety Standard Compliance Manager

13

2. General Warehouse Conditions 2.1. Stock Management and Traceability

3. Raw Materials Warehouse

13 13 15

3.1. Raw Material Traceability Traceability

15

3.2. Fiber Composition Analysis

15

4. Auxiliaries and Dyestuffs/Pigments Dyes tuffs/Pigments Warehouse

16

4.1. CTW, RTM and MRSL Hard Copies Availability

16

4.2. Auxiliaries and Dyestuffs/Pigments Information

16

4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabeling

18

4.4. Auxiliaries and Dyestuffs/Pigments Weighing

19

4.5. Dyestuffs/Pigments Specific Storage Conditions

21

4.6. Auxiliaries Specific Storage Conditions

22

5. Finished Goods Warehouse

23

5.1. Finished Goods Identification

23

5.2. Management of CTW Non Compliance Finished Goods

24

6. Work in Progress 6.1. Internal Orders Management

7. Dyeing and Washing 7.1. Dyeing and Washing Recipe

25 25 25 25

INDEX 8. Printing

26

8.1. Printing Conditions Criteria

26

8.2. Printing Recipe

28

8.3. Printing Paste Conservation

28

9. Water Discharge Effluents 9.1. Water Discharge Effluents Control 10. Production and Chemical Products Control

29 29 29

10.1. Analysis Requirements for Production Control

29

10.2. Chemical Products Selection

30

10.3. Chemical Products Suppliers Evaluation

31

10.4. Analysis Requirements for Chemical Products Control

32

10.5. Required Instrumentation for In-House Analysis

33

10.6. Outsourced Laboratories

35

10.7. Control Records

36

11. CTW Management

36

11.1. Purchase Orders to Suppliers

36

11.2. Documentation and Records

37

12. Annexes

39

Annex I. Template for Raw Materials and Greige Garments Traceability

40

Annex II. Template for Auxiliary Products and Dyestuffs/Pigments Stock Traceability

41

Annex III. Internal Order Template

42

Annex IV. Main Corrective Actions to Manage CTW/MRSL Non-Compliances

43

Annex V.a. Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production

44

Annex V.b. Workflow of the Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production

48

Annex VI.a. Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production

49

Annex VI.b. Workflow of the Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production 52 Annex VII. Dyeing/Printing/Washing Recipe Template

53

Annex VIII. Summary of In-House Analysis According to the Manufacturing Processes Carried Out

55

Annex IX. Analysis to be Performed In-House for Color Fasteness Control of the Production

56

Annex X. Analysis to be Performed In-House for pH Control of the Production

58

Annex XI. Analysis to be Performed in Outsourced Laboratories for Fiber Composition Control of the Production

59

Annex XII. Summary of the Chemical Products Subjected to Analysis

60

Annex XIII. Analysis to be Performed in Outsourced Laboratories for APEOs Control of Chemicals

61

Annex XIV. Analysis to be Performed in Outsourced Laboratories for PFCs Control of Chemicals

62

Annex XV. Summary of In-House Instrumentation According to the Manufacturing Processes Carried Out

63

Annex XVI. In-House Color Fastness Analysis Template for Production Control

64

Annex XVII. In-House pH Analysis Template for Production Control

66

Annex XVIII. Example of a Chemical Supplier Process Evaluation

68

INTRODUCTION

Introduction INDITEX has developed the manufacturing code “Ready To Manufacture” (hereinafter, RTM) with the aim of helping its suppliers to comply with the requirements of its product health standard “ Clear To Wear ” (hereinafter, CTW) and the “Manufacturing Restricted Substances List ” (hereinafter, MRSL).

This document will help you to implement the criteria and requirements to be applied in the facilities of 1

INDITEX direct suppliers as well as in the manufacturing processes, management of warehouses and chemical products and productions control of the dyeing and printing mills, laundries, tanneries and yarn, fabric or leather suppliers included in their supply chains.

In case you need further information related to RTM, please do not hesitate to contact INDITEX through the Corporate Social Responsibility Department (hereinafter, CSR). To this end, send an e-mail to [email protected] including in the subject the name of the INDITEX brand you are currently working for and/or you have received a purchase order from.

Scope 2

RTM covers INDITEX direct suppliers or sub-suppliers as well as the dyeing and printing mills, laundries and tanneries included in their supply chain.

Objective The main objective of RTM is to ensure that all INDITEX suppliers comply with CTW requirements and the MRSL resulted from the “ Zero Discharge of Hazardous Chemicals” (hereinafter, ZDHC).

3

INDITEX direct suppliers and the mills included in their supply chain into the scope of RTM will find in this document: • Textile and leather good manufacturing practices in order to deliver quality products. • Indications to improve technological skills of their facilities. • Procedures to ensure proper transmission of CTW and its implications to the entire INDITEX supply chain.

Thus, once these objectives will be achieved, both INDITEX and its suppliers will benefit of a reduction in manufacturing times and costs associated to article reprocessing due to CTW non compliances.

RTM Description RTM describes good manufacturing practices and best practices related to the different stages of the textile and leather manufacturing processes in order to ensure production traceability and CTW compliance.

1

Yarn, fabric, leather or garment suppliers who have a direct commercial relationship with INDITEX. Suppliers who provide goods to INDITEX direct suppliers and may have their own supply chain. They can be traders or vertically integrated suppliers. 3 https://www.inditex.com/en/sustainability/environment/manufacturing 2

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INTRODUCTION

RTM is structured in two chapters clearly separated “Good Manufacturing Practices and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers” and “Good Manufacturing Practices and Best Practices for Mills” included into the supply chain of INDITEX direct suppliers and sub-suppliers. 4

Important: In case an INDITEX direct supplier is vertically integrated, they should comply with the good manufacturing practices described in “Good Manufacturing Practices and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers” as well as in “Good Manufacturing Practices and Best Practices for Mills”. Additionally, compliance with best practices described in both chapters is highly recommended.

Good Manufacturing Practices Good manufacturing practices are basic requisites that should be implemented in order to achieve RTM objective. They are summarized and highlighted in red colour at the beginning of every section and their compliance is mandatory.

Best Practices Additionally, RTM includes best practices or recommendations to be implemented and which compliance is not mandatory but highly recommended . In the same way that the good manufacturing practices, best practices are summarized and highlighted in green colour and with a dotted line at the beginning of every section.

Note: Best practices are focused in those facilities with a commitment and engagement beyond merely complying with RTM good manufacturing practices.

RTM Implementation, Performance and Evaluation As previously mentioned, every INDITEX direct supplier or the dyeing and printing mills, laundries and tanneries included into their supply chain should comply, at least, with RTM good manufacturing practices. In order to verify RTM implementation and compliance, a self-audit questionnaire (hereinafter, SAQ) will be provided. This questionnaire includes questions about all good manufacturing practices included in RTM and only two answers are possible: “Yes” or “No”. Thus, RTM compliance is only ensured if all questions are positively answered. On the other hand, a negative answer means that there is a good manufacturing practice that is not being complied with what could lead to a potential CTW non compliance.

Note: SAQ is only a tool to help mills included in the supply chain of INDITEX direct suppliers or sub-suppliers to check RTM implementation. Thus, to send it back to INDITEX or any other third party is not needed.

Note: SAQ should be filled in for the mill responsible together with a representative of the INDITEX direct supplier they are working for.

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Supplier which participates in all or major stages of production of an article, from the acquisition of raw materials to its production and commercialization.

2

INTRODUCTION

Finally, INDITEX will conduct technical audits by means of its internal teams or outsourced and nominated service providers in order to evaluate RTM implementation. Technical audit results will be communicated to 5

INDITEX direct suppliers by means of INDITEX extranet. According to the results obtained in the technical audits, two different situations could happened: • Positive technical audit result (green color): The mill will be periodically audited by means of “Follow-Up Audits” in order to check that they continue to comply with RTM good manufacturing practices over time. • Negative technical audit result (red color): The auditor will provide a corrective action plan to the mill that should be implemented over an agreed time period to ensure that the mill has the opportunity to meet RTM good manufacturing practices. Afterwards, a second technical audit will happen that in case of a positive technical audit result (green color) will be followed by the previously described procedure of regular visits or “Follow-Up Audits”. Conversely, if the result of the technical audit is negative (red color), the commercial department of the INDITEX brand working with this mill will be informed what may result in temporary or permanent blocking of purchase orders (hereinafter, PO’s) to this mill.

Important: Remember that RTM good manufacturing practices compliance does not exclude full CTW compliance.

Key Definitions In order to help in RTM comprehension there are different concepts that should be previously defined: • Auxiliary products or auxiliaries:RTM considers auxiliaries to the chemicals used during the manufacturing processes of textile and leather articles without comprising dyestuffs/pigments and chemical commodities (acids, sodium chloride, sodium sulphate, so dium carbonate, chromium sulphate, caustic soda, hydrogen peroxide, sodium hydrosulphite, among others).

• Batch: RTM considers a batch to each yarn, fabric, leather or garment delivery from the same supplier, produced at the same mill, using the same recipe and by means of the same manufacturing process, regardless the number of shipments and their date. As an example, see the following situations: o 1 PO supplied by two different suppliers will be considered as two batches. o 1 PO supplied by the same supplier but in two different dates will be considered as one single batch only if it was manufactured in the same mill, with the same recipe and by means of the same manufacturing process.

• Dyeing lot: RTM considers a dyeing lot to the quantity of yarn, f abric, leather or garments that have been dyed simultaneously, using the same machinery and the same recipe.

Note: Mixing of different dyeing lots should be avoided during storage and the manufacturing process.

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https://extranet.inditex.com/extranet

3

INTRODUCTION

•

Dyeing lot number:

traceability purposes.

•

Internal order number: RTM considers internal order number to the code assigned to each processing

subset of yarn, fabric, leather or garments from one initial PO.

•

Lot number:

supplier assigns to their chemical products for traceability purposes.

•

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Manufacturing Restricted Substances List (MRSL): Register of chemical substances that are subject

to a usage ban/restriction during the manufacturing process of an article in order to comply with the “Zero Discharge of Hazardous Chemicals” (ZDHC).

•

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Printing lot: RTM considers a printing lot to the quantity of fabric, leather or garments that have been

printed simultaneously, using the same machinery and the same recipe or until the printing panels or rotary screens are cleaned.

Note: Mixing of different printing lots should be avoided during storage and the manufacturing process.

•

Printing lot number: RTM considers a printing lot number to the identification code assign to a

printing lot for traceability purposes.

•

Product to carry out special effects: RTM considers products to carry out special effects all

chemicals comprised in the following categories: o Transparent printing base pastes. o White and lac pastes. o Foam pastes. o Foil/transfer adhesive. o Glitter paste. o High density pastes and puff pastes. o Pigment gloss and metal effect pastes. o 3D products.

o Cationic/mordanting agents. o Wool protectors. o UV curing agents and additives.

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https://www.wateractionplan.com/ https://www.inditex.com/en/sustainability/environment/manufacturing

4

INTRODUCTION

• Raw materials: RTM considers raw materials to flat knitted yarn, fabric and leather.

• Recipe: Dyestuffs/pigments and auxillaries formulation use to dye, print or wash yarn , fabrics, leather or garments.

Note: In case lot number and/or concentration o f any of the chemicals used changes, it will be considered as a different recipe.

• Small part or accessory: RTM considers a small part or accessory to an independent element of the finished article characterized by: o Low manufacturing control. o Low stock traceability. o Independent manufacturing process to the rest o f the article. o Incorporated to the article at the final stage of its manufacturing process.

• Washing lot: RTM considers a washing lot to the quantity of fabric, leather or garments that have been washed simultaneously, using the same machinery and the same recipe.

Note: Mixing of different washing lots should be avoided during storage and the manufacturing process.

• Washing lot number: RTM considers a washing lot number to the identification code assign to a washing lot for traceability purposes.

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GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR INDITEX DIRECT SUPPLIERS AND SUB-SUPPLIERS


A. Good Manufacturing Practices and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers 1. INDITEX Direct Supplier and Sub-Suppliers Staff 1.1. INDITEX Product Health and Safety Standard Compliance Manager.

INDITEX Product Health and Safety Standard Compliance Manager Knowledge Profile. INDITEX Product Health and Safety Standard Compliance Manager in the Different Mills of a Vertically Integrated INDITEX Direct Supplier. 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager.

Attendance to INDITEX Meetings for Direct Suppliers. Workshop for Supply Chain CTW Training.

1.1. INDITEX Product Health and Safety Standard Compliance Manager Every INDITEX direct supplier or sub-supplier should have a designated person for all health and safety issues related to INDITEX Product Health Standard, “Clear To Wear ” (hereinafter, CTW). This person should have a deep knowledge of this standard and attend all INDITEX training programs described in the following section “1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager”. 8

In case that an INDITEX direct supplier is vertically integrated, the INDITEX product health and safety standard compliance manager should ensure that purchasing, production line and technical area managers are deeply aware of CTW requirements. 9

Note: In case that a sub-supplier is included into the supply chain of an INDITEX direct supplier, both this sub-supplier and their corresponding dyeing and printing mills, laundries and tanneries should also have their corresponding INDITEX product health and safety standard compliance manager. In the same way, all facilities 10

into the supply chain of a sub-supplier should be registered in INDITEX extranet by the corresponding INDITEX direct supplier.

Important: INDITEX product health and safety compliance manager role can be played by one of the workers already hired and does not imply to hire one more person since only a deep knowledge of CTW is needed.

8

Supplier which participates in all or major stages of the production of an article, from the acquisition of raw materials to its production and commercialization. 9 Suppliers who provide goods to INDITEX direct suppliers and may have their own supply chain. They can be traders or vertically integrated suppliers. 10 https://extranet.inditex.com/extranet

7


Best Practice: Recommended INDITEX product health and safety standard compliance manager knowledge profile should include the following issues: • A minimum of 2 years of experience in the textile and/or leather wet processing. • Knowledge of auxiliaries, dyestuffs/pigments and industrial processes related to the textile and/or leather processing industry. • Basic knowledge of legislation related to the textile or leather processing industry as well as the chemical tests for their control. • Basic knowledge of environmental legislation and parameters related to the discharge of water effluents.

Best Practice: In case that an INDITEX direct supplier is vertically integrated and has several mills in different geographical locations, it is highly recommended to have an INDITEX product health and safety standard compliance manager in all of them.

1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manag er The INDITEX product health and safety standard compliance manager should become the in-site internal trainer for the rest of the workers. In order to be continuously updated about INDITEX policies, this person should attend to all INDITEX training programs which include: • e-CTW&STW program: An educational program developed in order to inform, train and support all suppliers about CTW requirements and, help them to reach its requirements. This program is carried out by means of webinars (web conferencing meetings) which allow internet conferencing events in real time with remote locations. • Technical Audits (TA´s): Visits performed to INDITEX direct suppliers or sub-suppliers by the most skilled team of experts in textile and leather industry globally nominated by INDITEX to assure CTW and MRSL requirements compliance.

Best Practice: The INDITEX product health and safety standard compliance manager should also attend: • INDITEX supplier´s meetings: periodically organized by INDITEX in order to inform, train and aware suppliers in the compliance of CTW and MRSL requirements.

Best Practice: INDITEX direct suppliers should organize workshops about CTW and MRSL requirements for both their internal staff and the mills included in their supply chain. Workshops records should be maintained for at least 2 seasons (12 months approximately).

8


2. Traceability Documents 2.1. Purchase Orders to Suppliers. 2.2. Documentation and Records.

2.1. Purchase Orders to Suppliers All purchase orders (PO’s) to suppliers should be in written form and including INDITEX PO number and brand the PO belongs to. Additionally, PO’s should also mention the fo llowing remark: • All goods related to this PO should comply with the latest version of CTW and MRSL.

Important: In case PO includes goods for babies (0-3 years old) it should be also mentioned and highlighted.

Important: Oral communications should be always avoided.

2.2. Documentation and Records All INDITEX direct suppliers should have a documentation management system in order to ensure production control traceability and their appropriate implementation.

According to this, following is a summary of all documents that should be stored and maintained: • CTW and MRSL compliance commitment from all suppliers (excluding chemicals suppliers) and mills into their supply chain of the INDITEX direct supplier or sub-supplier. o INDITEX direct suppliers or sub-suppliers should get from every mill included into their supply chain and also from every supplier (excluding chemical suppliers), a written and dully signed commitment stating that they know and understand both CTW and MRSL and that all the goods provided by them will comply with their requirements.

Important: Please, note that every time an INDITEX direct supplier decides to include a new mill into their 11

supply chain, it should be registered on INDITEX extranet. In order to have the supply chain information always updated, it is mandatory to register all facilities used in the last 12 months and that may be used in the near future. Additionally, any change on it should be also registered as soon as possible and without waiting for an INDITEX PO.

• Hard copies of all documentation related to CTW, RTM and documents related to the technical audits conducted to your facilities and the mills included into their supply chain.

• INDITEX PO´s.

11

https://extranet.inditex.com/extranet

9


• PO´s sent to the mills included into their supply chain.

• Shipment delivery notes to the mills included into their supply chain.

• Shipment delivery notes from the mills included into the supply chain of an INDITEX direct supplier or sub-supplier to the INDITEX direct supplier of sub-supplier.

• Fiber composition analysis test report for every raw material (except leather) batch purchased: o Fiber composition analysis test report should be provided by the raw material supplier and performed in accordance with section “10.1. Analysis Requirements for Production Control”. Additionally, INDITEX direct supplier or sub-supplier should provide this information to the dyeing and/or printing mills included in their supply chain before starting the production of the article.

Note: In case of textile processes which could change composition (i.e. carding yarn articles, napping, brushing, enzymatic washings, “devore”/burnout printing, among others), composition analysis should be performed at the end of these processes and it will be exclusive responsibility of the INDITEX direct supplier.

Important: Initially, INDITEX direct supplier or sub-supplier should have the required information available for the current season. Eventually, it should be updated until covering the last 2 seasons (approximately 12 months).

Important: In case an INDITEX direct supplier or sub-supplier is vertically integrated, they should also comply with good manufacturing practices shown in the following chapter of this document “Good Manufacturing Practices and Best Practices for Mills”.

Important: RTM compliance does not exclude full CTW compliance. According to this, all INDITEX direct suppliers should ensure that finished goods comply with CTW requirements previously to their shipment to INDITEX.

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TÍTOL

GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS

11


B. Good Manufacturing Practices and Best Practices for Mills 1. Mill Staff 1.1. INDITEX Product Health and Safety Standard Compliance Manager.

INDITEX Product Health and Safety Standard Compliance Manager Knowledge Profile. 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager.

Attendance to INDITEX Meetings for Direct Suppliers and the Mills Included in their Supply Chain. Workshop for Internal CTW Training.

1.1. INDITEX Product Health and Safety Standard Compliance Manager Every yarn, fabric or leather supplier, dyeing and printing mill, laundry or tannery into the supply chain of an INDITEX direct supplier or sub-supplier should have a designated person for all health and safety issues related to INDITEX Product Health Standard, “Clear To Wear ” (hereinafter, CTW). This person should have a deep knowledge of this standard and attend all INDITEX training programs described in the following section “1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager”. Additionally, this person should also ensure that purchasing, production line and technical area managers are deeply aware of CTW requirements.

Important: INDITEX product health and safety compliance manager role can be played by one of the workers already hired and does not imply to hire one more person since only a deep knowledge of CTW is needed.

Best Practice: Recommended INDITEX product health and safety standard compliance manager knowledge profile should include the following issues: • A minimum of 2 years of experience in the textile and/or leather wet processing. • Knowledge of auxiliaries, dyestuffs/pigments and industrial processes related to the textile and/or leather processing industry. • Basic knowledge of legislation related to the textile or leather processing industry as well as the chemical tests for their control. • Basic knowledge of environmental legislation and parameters related to the discharge of water effluents.

12


1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager The INDITEX product health and safety standard compliance manager should become the in-site internal trainer for the rest of the workers. In order to be continuously updated, this person should attend to all technical audits carried out in the mill: • Technical Audits (TA´s): Visits performed to the mills included in the supply chain of INDITEX direct suppliers by the most skilled team of experts in textile and leather industry globally nominated by INDITEX to assure CTW and MRSL requirements compliance.

Best Practice: The INDITEX product health and safety standard compliance manager should also participate in the following training programs: • INDITEX supplier´s meetings: periodically organized by INDITEX in order to inform, train and aware suppliers and the mills included in their supply chains in the compliance of CTW and MRSL requirements. • e-CTW&STW program: An educational program developed in order to inform, train and support all INDITEX direct suppliers and the mills included in their supply chains about CTW requirements and, help them to reach its requirements. This program is carried out by means of webinars (web conferencing meetings) which allow internet conferencing events in real time with remote locations.

Best Practice: Mills should organize workshops about CTW and MRSL requirements for internal staff. Workshops records should be maintained for at least 2 seasons (12 months approximately).

2. General Warehouse Conditions This section comprises all good manufacturing practices and best practices common to all warehouses involved in the textile and leather manufacturing processes. However, in later sections, specific good manufacturing practices and best practices for raw materials, auxiliaries, dyestuffs/pigments and finished goods warehouses will be also covered.

2.1. Stock Management and Traceability.

Printed Traceability Documents. Use of Location Markers.

2.1. Stock Management and Traceability All stored goods should be always identified by at least, their lot number in the case of dyestuffs/pigments and auxiliaries or, their batch number fo r raw materials.

13


Incoming raw materials (yarn, fabrics or leather) and greige garments sho uld be always registered including all information shown in Annex I.

Stock of auxiliaries and dyestuffs/pigments should be always updated. For this reason, their stock should be monthly registered including all information shown in Annex II.

Note: In case stock management is automated, the register of chemicals should be printed once a month in order to have it always available.

Important: Annex I and Annex II templates are for guidance only. Alternatively, any other format which includes, at least, all the information required in these templates can be used.

Note: Traceability of products which could be stored outdoor (raw materials and auxiliaries) should be always ensured, even under extreme weather conditions.

Best Practice: In order to avoid confusions, all traceability documents of stored aticles should be always typed. To ensure the identification of hides, skins and leather in tanneries, traceability codes should also be stamped on their surface.

Goods properly identified

Goods without proper identification

Best Practice: Location markers should be used for proper location and identification of goods.

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Goods properly identified with location markers

3. Raw Materials Warehouse 3.1. Raw Material Traceability. 3.2. Fiber Composition Analysis.

3.1. Raw Material Traceability Incoming raw materials should be identified by their batch number which should be incorporated to an internal order template including all information shown in Annex III. To ensure an appropriate traceability, internal order number should accompany the goods along their manufacturing process and storage. Important: Annex III template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used.

3.2. Fiber Composition Analysis Along with every batch of flat knitted yarn or fabric provided to a dyeing or printing mill, a composition analysis should be provided. The analysis should be performed by the raw material supplier according to section “10.1. Analysis Requirements for Production Control” and provided to the mill by the INDITEX direct supplier or subsupplier before the production starts. However, in case composition analysis is not provided by the INDITEX direct supplier or sub-supplier, composition analysis should be performed directly by the dyeing or printing mill. Important: In case batch number information is not available, a composition analysis should be performed after every reception of a new raw material shipment. Note: In case of textile processes which could change composition (i.e. carding yarn articles, napping, brushing, enzymatic washings, “devore”/burnout printing, among others), composition ana lysis should be performed at the end of these processes and it will be the exclusive responsibility of the INDITEX direct supplier.

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4. Auxiliaries and Dyestuffs/Pigments Warehouse 4.1. CTW, RTM and MRSL Hard Copies Availability.

CTW, RTM and MRSL Hard Copies Availability in Close Proximity to Chemicals. 4.2. Auxiliaries and Dyestuffs/Pigments Information.

SDS and TDS Availability in Close Proximity to Chemicals. Translation of SDS and TDS Key Information into Local Language. 4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabeling. 4.4. Auxiliaries and Dyestuffs/Pigments Weighing.

Auxiliaries and Dyestuffs/Pigments Auto Dosing System. Auxiliaries and Dyestuffs/Pigments Weighing Responsible Person. Balance Proximity to Auxiliaries and Dyestuffs/Pigments. Auxiliaries and Dyestuffs/Pigments Balance Calibration. 4.5. Dyestuffs/Pigments Specific Storage Conditions.

Dyestuffs/Pigments Warehouse Door or Polymer Curtain. Proper Opening of the Dyestuff/Pigment Containers. 4.6. Auxiliaries Specific Storage Conditions.

4.1. CTW, RTM and MRSL Hard Copies Availability CTW, RTM and MRSL hard copies should be always available on-site.

Best Practice: CTW, RTM and MRSL hard copies should be stored close to a uxiliaries and dyestuffs/pigments for ease of reference if necessary.

4.2. Auxiliaries and Dyestuffs/Pigments Information All incoming auxiliaries and dyestuffs/pigments should be properly identified by means of their original labeling which should always include lot number, chemical product and manufacturer/distributor names.

In case, a chemical product does not include all this information or it does not comply with CTW and/or MRSL requirements, it should be considered as a CTW and/or MRSL non compliant product, highlighted and store segregated.

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Dyestuff which does not comply with CTW requirements perfectly identified and segregated

Auxiliaries which does not comply with CTW requirements perfectly identified and segregated

Note: Auxiliaries or dyestuffs/pigments which labels have been totally or partially removed or include hand written information will not be allowed. In the same way, to remove or hide total or partially their original label information will be also not accepted.

Dyestuff containers with hand written labels and which labels from their original manufacturer/distributor have been removed

Additionally, along with the reception of an auxiliary product, dyestuff or pigment for the first time, its Safety 12

13

Data Sheet (SDS) and Technical Data Sheet (TDS), completed and updated, should be included. Additionally, in case of any update in the SDS or TDS, it should be sent again by the chemical supplier.

Note: Every SDS should be checked to ensure the chemical product does not contain any restricted substance included in the MRSL or the content of this substance is not above CTW requirements.

Best Practice: SDS and TDS should be stored close to auxiliaries and dyestuffs/pigments for ease of access if necessary.

12

Document which describes the hazards associated with a chemical product. They list hazardous ingredients (i.e. formaldehyde), types of hazards present and ways that workers should handle the materials and protect themselves. 13 Document which summarizes the application mode and other technical characteristics of a chemical product.

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Best Practice: Auxiliary products, dyestuffs or pigments instructions for use as well as their main potential CTW non compliance issues from SDS should be translated into local language to ensure all workers understanding. Appropriate signs and pictures can be included to highlight key points and reinforce the information.

SDS key issues translated into local language

4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabeling Auxiliaries and dyestuffs/pigments repackaging and relabeling should be always avoided and carried out only in case it is strictly necessary. If this happens, new containers should include a label that ensures traceability to the original one.

Additionally, every time the relabeled container is refilled with a different lot number product, its label should be updated.

Repackaging of dyestuffs with the original labeling attached at their upper lid

Repackaging of dyestuffs without proper identification

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Important: Do not mix auxiliaries or dyestuffs/pigments with different lot numbers in the same container. In the case of auto dosing systems minimize the mix of different lot numbers as far as possible.

4.4. Auxiliaries and Dyestuffs/Pigments Weighing In order to avoid cross contamination during auxiliaries and dyestuffs/pigments weighing, next indications should be followed: • Dyestuffs/pigments and auxillaries should be always weighed carefully. In the specific case of solid dyestuffs (powder, (powder, grains and flakes), they should be always weighed independently and then, put together in one single container.

Correct practice

Incorrect practice

• Every auxiliary product, dyestuff or pigment should have its own weighing accesory (jar, bucket, spoon, among others) which should be properly identified and traceable to the product they are used for.

Dyestuff container with its weighing spoon properly identified

Auxiliaries without their own weighing accessories

• Containers re-use or modification to ease auxiliaries or dyestuffs/pigments dispense is not allowed.

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Use of original auxiliaries containers

Use of no original auxiliaries containers modified by including a tap in their bottom

• Auxiliaries and dyestuffs/pigments weighing balance should be always placed in a clean, dry and, flat surface for proper weighing and to avoid any risk of contamination.

Balance in a clean, dry and flat surface

Balance under inappropriate conditions

Note: In case the balance is equipped with a level indicator, make sure that it is in the position which implies that this instrument is well-balanced.

Best Practice: Auto Practice: Auto dosing systems are highl highly y recommend re commended ed since si nce they t hey can reduce the risk r isk of exposur exposure, e, spillage spilla ge and wastag e of a uxilia uxiliaries, ries, dyestuf dyestuffs fs and an d pigments. pigme nts.

Best Practice: Auxiliaries Practice: Auxiliaries and dyestuffs/pigments handling and weighing should be always carried out by one trained and designated person and if possible, in a segregated a rea from the chemical warehouse.

Best Practice: Auxiliaries Practice: Auxiliaries and dyestuffs/pigments weighing should be carried out once they are placed close to the balance as carrying small product amounts over large distances can lead to inaccuracy and potential cross contamination.

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Best Practice: Balance needs to be periodically calibrated according to manufacturer recommendations. Once calibrated, records should be properly maintained.

4.5. Dyestuffs/Pigments Specific Storage Conditions All dyestuff/pigment containers should be stored indoor, avoiding direct contact with the floor and walls and according to what was previously described in section “2. General Warehouse Conditions”. Conditions”. Additionally, dyestuff and pigment containers should be always stored closed and will be opened only for weighing.

Proper dyestuff storage

Improper dyestuff storage

Best Practice: Since most particles of powdered dyestuffs are low specific gravity, gravity, dyestuff warehouse should be equipped equipped with a door or at least, least, a plastic plastic polymer curtain in order to avoid the contamination of other areas of the mill.

Dyestuff warehouse equipped with a door

Dyestuff warehouse equipped with a polymer curtain

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Best Practice: Dyestuff containers should be opened following chemical supplier indications to ensure that the upper side of the container can be used as its lid.

Dyestuff containers properly opened

Dyestuff containers improperly opened

Best Practice: To keep and maintain a sample o f every dyestuff/pigment lot number used for all INDITEX PO’s received during the last season (approximately 6 months) is highly recommended. In the case of printing mills, it is also highly recommended to keep and maintained samples of all lot numbers of thickeners, binders, resins or any other aromatic polyurethane (PU) based products used during the period previously mentioned.

4.6. Auxiliaries Specific Storage Conditions To avoid potential cross contamination, auxiliaries in solid and liquid form should be stored in segregated areas.

Liquid and solid auxiliaries stored segregated

Liquid and solid auxiliaries improperly stored

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5. Finished Goods Warehouse 5.1. Finished Goods Identification. 5.2. Management of CTW Non Compliance Finished Goods.

Register of Detections/CTW Non Compilances.

5.1. Finished Goods Identification Finished goods should be stored indoor, avoiding direct contact with the floor and walls and according to what was previously described in section “2. General Warehouse Conditions”. Additionally, finished goods should be identified with at least, their internal order number which should be traceable to the corresponding internal order template which should include all the information shown in Annex III.

Important: Annex III template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used.

Finished goods storage with an appropriate traceability and avoiding direct contact with the floor

Finished goods storage without proper traceability and in direct contact with the floor

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5.2. Management of CTW Non Compliance Finished Goods In the case that despite all efforts made during the manufacturing process finished goods do not comply with CTW requirements, they should be highlighted and stored in segregated areas.

CTW non compliance finished goods highlighted in red colour and store segregated

Additionally, the next procedure should be followed: • Identify the source of the incidence. • Halt the manufacturing process until the issue is properly identified and solved. • Inform the customer, the INDITEX direct supplier, who should contact the Corporate Social Responsibility (here in after, CSR) Department product health and safety area responsible and/or the commercial agent of the INDITEX brand which placed the order to know the corrective actions to be implemented. • Put in place the corrective actions to manage CTW non-compliances and to prevent their recurrence in future productions (see Annex IV).

Best Practice: All incidences related to detections or CTW non compilances should be registered and maintained.

Finally, you may be required by the INDITEX CSR Department product health and safety area to be enrolled in a Root Cause Analysis (RCA) audit in order to evaluate and identify the source of an incidence found in an article produced in your facilities and delivered to INDITEX and to prevent it in the future.

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6. Work In Progress 6.1. Internal Orders Management.

6.1. Internal Orders Management In order to have proper traceability throughout the entire manufacturing process, work in progress should be always identified by their corresponding internal order number which should be traceable to the internal order template (see an example in Annex III ). This template should include all the information related to the goods that are being manufactured and the different processes they are being subjected to.

Important: Annex III template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used.

7. Dyeing and Washing 7.1. Dyeing and Washing Recipe.

Liquor Ratio Control. Dyeing and Washing Parameters Automated Control Machinery. Indirect Steam Dyestuff/Pigments Dissolution.

7.1. Dyeing and Washing Recipe An independent dyeing or washing recipe should be filled in for every dyeing or washing lot. This recipe should include all the information shown in Annex VII.

Important: In case dyeing or washing recipe includes any codification of a chemical product, its traceability to the commercially available chemical product name should be ensured.

Important: Annex VII template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. 14

Best Practice: In order to obtain an appropriate reproducibility and colour fastness results, liquor ratio should be controlled during dyeing.

Best Practice: All dyeing and washing machinery should be microprocessor based controlled in order to control all key parameters of the process, especially temperature and time, to ensure a ppropriate reproducibility and colour fastness results.

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Weight of yarn, fabric or garment to bath proportion.

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