1. SER PROGRAMME
(Social and Environmental Responsibility Programme)

2. Contents
• Preamble
• Compliance
• Social Standards
• Environmental Conduct
• Workplace Health & Safety
• Product Safety

3. Preamble
Leighmans.com is aware that successful and sustainable business
performance can only be attained when responsibility for its
clients, employees, the company and the environment can be seen to be
taken. Leighmans.com has decided to act on this awareness by
committing to the following programme. It comprises the basic demands
of the Business Social Compliance Initiative, the guidelines of the
Promotional Products Association International (PPAI), and the
conventions of the International Labour Organization (ILO, www.ilo.org)
as well as the company’s own goals.
This programme relates to both company processes and products.
With respect to products which are not manufactured by Leighmans.com
itself, this programme is also to be complied with by the original suppliers
(OES, 1st tiers) and their suppliers (2nd tiers), as the basis of their
cooperation. The aim is to ensure that the expectations of our
customers, the society, and the respective authorities are fully met.

4. Preamble
These expectations are:
• Compliance with legal requirements
• Conformity with social standards
• Observance of ethical principles
• Avoidance of hazards to people and the environment
• The protection of resources in conservation of the
• environment
• The minimisation of the effects of pollution on people
and the
• Environment

5. Preamble
This is only possible if all the parties involved undertake to
act in accordance with this programme.
In order to implement the programme together with our
suppliers and partners and to check its progress, we will
audit our processes, suppliers and partners all over the
world.
In this way, we can guarantee that the aspects covered in
this programme are met and that our international quality
lead for our products is maintained, thereby also securing
the success of the company for the future. This is only
possible if all the parties involved undertake to act in
accordance with this programme.

6. Compliance with Legal Requirements
Leighmans.com products are sold all over the
world. This means that not only must the
legal regulations of the country of
manufacture be complied with respect to
processes and products, but the legal
requirements of the respective markets must
also be adhered to.

7. Compliance with Legal Requirements
Legal requirements apply with respect to the following (and other)
aspects:
• Raw materials
• Operational facilities, health and safety at work
• Work times and wages
• Human rights and social responsibility on the part of the
• employer
• Production processes
• Refuse disposal processes
• Packaging
• Ready-made products
• Product information and user instructions/product
• Declarations

8. Compliance with Legal Requirements
The laws prevailing in the country of
manufacture are of course to be observed
and complied with by the respective
manufacturer, at their own responsibility. The
legal requirements of the sales markets are
listed in the respective product specifications
or quality agreements by Leighmans.com.

9. Social Standards
Leighmans.com commits to the eight fundamental
principles of the International Labour Organization
(ILO, www.ilo.org) which is an organization of the
United Nations (UN) and moreover Leighmans.com
commits to the demands of “Social Accountability
International” (SAI,www.sa-intl.org) which are
integrated as elements in the international ethical
workplace management system SA 8000

10. Social Standards
• Freedom of association and right to collective bargaining with employers
• No forced labour like work or service which is exacted from any person under
the menace of any penalty and for which the said person has not offered
himself voluntarily; forbiddance of forced or compulsory labour as a means of
political coercion or education or as a punishment for holding or expressing
political views or views ideologically opposed to the established
political, social or economic system; as a means of labour discipline; as a
punishment for having participated in strikes; and as a means of
racial, social, national or religious discrimination
• No corporal punishment, mental or physical coercion or verbal abuse
Minimum Age for special work, forbiddance of employment and misuse of
children
Minimum Age for special work, forbiddance of employment and misuse of
children

11. Social Standards
• Equal remuneration for men and women workers for work of equal value; no
discrimination race, colour, sex, religion, political opinion, national extraction
or social origin, handicap, union or political affiliation, no sexual harassment.
• Provide a safe and healthy work environment; take steps to prevent injuries;
regular health and safety worker training; system to detect threats to health
and safety; access to bathrooms and potable water
• Working hours: Comply with the applicable law but, in any event, no more
than 48 hours per week with at least one day off for every seven day period;
voluntary overtime paid at a premium rate and not to exceed 12 hours per
week on a regular basis; overtime may be mandatory if part of a collective
bargaining agreement
• Compensation: Wages paid for a standard work week must meet the legal
and industry standards and be sufficient to meet the basic needs of workers
and their families; no disciplinary deductions

12. Environmental Conduct
• Conduct that shows due concern for the environment relates to the
company, its manufacturing processes and products.
• Suppliers of Leighmans.com maintain environmental management systems
which cover the consumption of resources and energy as well as refuse
disposal processes. When investing in new machinery and initiating new
processes, great attention is paid to attaining the highest possible level of
energy efficiency.
• If possible own production refuse is recycled and for example, substitutes
about 20% of raw material in the pen production which is saved. All
production waste in our factories is subjected to re-use/ reutilisation. For
instance, waste metal from refill tip production is degreased, melted down and
made into new material for refill tips. The oil which is washed out is also
utilised.
• Waste from offices is sorted, with paper and card being separated from the
general refuse, and recycled or used for energy generation.

13. Environmental Conduct
• Solvent-based refuse are disposed off by certified refuse companies
and also used as substitute fuel.
• Mixed plastic refuse, which cannot be reincorporated in the production
process, is removed by outside companies and used as a raw
material for other processes.
• Inks are supplied in returnable containers.
• 90 % of paperboard containers of raw mug green ware is reused as
shipping packaging for finished goods. The waste heat of the mug
kilns is used for heating the production hall. Most of the industrial
waste heat of the exhaust air is recaptured by heat exchangers for to
temper the fresh air.

14. Environmental Conduct
• Solvent-based refuse are disposed off by certified refuse companies
and also used as substitute fuel.
• Mixed plastic refuse, which cannot be reincorporated in the production
process, is removed by outside companies and used as a raw
material for other processes.
• Inks are supplied in returnable containers.
• 90 % of paperboard containers of raw mug green ware is reused as
shipping packaging for finished goods. The waste heat of the mug
kilns is used for heating the production hall. Most of the industrial
waste heat of the exhaust air is recaptured by heat exchangers for to
temper the fresh air.

15. Environmental Conduct
Moreover, Leighmans.com attaches top priority to the following
product properties:
• Reusability
• Long product life-cycle due to high value, robustness and
permanent
• sturdiness
• Can be dismantled and individual parts recycled into reusable
• raw materials
• Protection of resources by using high rate of recycled
• materials
• Biological degradability and compostability by selecting particular
• materials for particular products
• Waste reduction by using optimised packaging

16. Environmental Conduct
• Leighmans.com products only use processes and materials that are
guaranteed free of pollutants within statutory limits. Leighmans.com
requires that its suppliers and OEMs adhere to the respective legal
standards with their products.
• The use of unwanted or statutory limited substances like for instance
heavy metals, polycyclic aromatic hydrocarbons, special phthalates,
polychlorinated/-bromated biphenyls, carcinogenic or mutagenic
substances and so on is avoided in the production processes or, where
not avoidable, severely supervised for to exclude health risks for
employees and exposure of the environment. For to limit the content of
these substances in finished products only raw materials are used which
comply with these specifications and it is ensured that such unwanted
substances can’t enter the flow of material.
• Adherence to these standards is subjected to random checking by
accredited test laboratories.
• Protection of the environment by applying robust and durable products is a
matter of great importance to Leighmans.com. We achieve this primarily
as a result of our high quality standards and our functional and aesthetic,
high-quality styling, for which we have received numerous awards.

17. Workplace Safety & Health
• Workplace safety relates to the handling of dangerous substances
and operating materials or materials which can endanger health.
• Besides the before described avoiding or limiting unwanted
harmful to health substances or environmental pollution
substances special measures for the use of dangerous substances
are done. The maximum allowed concentration of volatile organic
compounds (VOC) is undercut through sufficient ventilation and air
extraction.
• Dangerous areas of production facilities are secured by protection
guards or other protective devices, to prevent unintentional
personal injury. Safety devices are connected to automatic
shutdown mechanisms; production facilities will therefore only
function when the safety device is applied.

18. Workplace Safety & Health
• Employees are trained in handling such equipment before they
take up their work. Moreover, workplace safety seminars are held
regularly; these are compulsory and attendance is checked.
• Such measures are for example in Germany outlined in legal
accident prevention directives (UVV) which are strictly adhered.
• Leighmans.com also expects the same standards of its suppliers;
adherence is checked in the form of audits

19. Product Safety
Leighmans.com products which are marketed for use by children fulfill the
requirements of child safety as per DIN EN 71, ISO 11540:1993 and BS 7272-
2:2000 and ASTM F963. Should they contain small parts which are in danger of
being swallowed by babies or small children, they are marketed by
Leighmans.com with a notification of age restriction; they are designed so as not
to present a choking hazard and to ensure that they present no health risk.
General product safety is ensured by avoiding sharp corners and edges and
adopting a design review in the development of the product which comply with
the European directive 2001/95/EC (product safety).
Only non-toxic writing pastes and inks are used.
The legal requirements of the key markets (Europe, USA, Russia, India and
China) concerning the ingredients of Leighmans.com-products are adhered.

20. Product Safety
These are e.g. the European directive concerning limiting of
dangerous/hazardous substances and preparations
(76/769/EEC), in which many substances as for example heavy
metals regulated, and the respective revisions and
amendments, e.g.:
• 2002/61/EC: ban of special AZO-colourants
• 2002/45EC: short chain chlorinated paraffines
• 2003/11/EC: penta- and octabromated diphenylethers
• 1999/43/EC: special carcinogenic colourants
• 2005/84/EC: ban of phthalates with risks for health
• Eminently important for the American market are:
• US Toxic Substances Control Act (TSCA)
• Federal Hazardous Substances Act
• California Proposition 65

21. Product Safety
Art materials / products like e.g. fibre pens, crayons, pencils, inks or fountain pen
nibs have to comply with ASTM D-4236 and ASTM F963 it they are provided for
the use through children.
Substances like heavy metals, polyaromatic hydrocarbons (PAH), polychlorinated
and –bromated biphenyls and nonylphenole are especially checked. Parts, which
may have enduring skin contact don’t contain natural latex what can cause
allergies (thea are “latex free”).
Mugs and products, which are designated for to come in contact with food
furthermore are liable to the European directive 2005/31/EG.
Other important standards and rules for Leighmans.com-products are e.g. ISO
12757 (ballpen refills), EN 71 (safety of toys) or EN 1811 and EN 12472 (nickel
abrasion). This listing is based on the acquaintance at declaration date of this
programme and isn’t complete but should demonstrate exemplary which high
requirements are related to Leighmans.com-products.

22. Product Safety
To achieve compliance with these standards following measures are done by
Leighmans.com:
Leighmans.com only employs raw materials which are safe to use and have been
tested to ensure that they are free of pollutants subject to permissible limits.
Leighmans.com only buys from suppliers who have been approved following due
inspection and extensive auditing and who guarantee that that their products
comply with the laws and directives concerning limited pollutants.
Leighmans.com performs (random) checks to ensure conformity with legal
requirements concerning limited pollutants.
Leighmans.com has established a comprehensive approval process for new
products, which covers product safety aspects.
Leighmans.com only charges accredited institutes to perform chemical analyses.

23. SER PROGRAMME
(Social and Environmental Responsibility Programme)