We Promise To Protect Your Brand As If It Were Our Own

We Promise To Protect Your Brand As If It Were Our Own Our Pledge We Promise To Protect Your Brand As If It Were Our Own Responsibility to protect product recipients from harm, protect your company and protect your brand. Product safety is a top priority. The Vernon Company understands the importance of having safe, compliant products to represent you and your brand.  Providing our clients with safe, tested and approved products is a commitment we’ve taken to heart. That’s why we put together one of the most extensive product safety initiatives in our marketplace. “Protect Your Brand” is a comprehensive program that ensures our clients receive products that comply with all environmental, social and product safety standards. 

What is Product Compliance? Product compliance is the assurance that products you give your target audience meet environmental, social and product safety regulations and standards. When you make an investment to promote your brand, it’s important to make sure you are protecting it too, with compliant products. Be responsible! Everyone in the product chain (from manufacturers, to suppliers, to the companies who buy and distribute the product) is responsible for providing safe products that will not cause harm to the product recipient.

Why should you care? Compliance with federal and state regulations is NOT optional. It is the law. Non-compliance results in: Hefty fines Damaged brand image Lost customers Worst case: injuries to people or environment Establish or maintain an organizational reputation of product safety

How did we get here? High profile recalls 2010, Wegman’s grocery bags 2010, McDonalds Shrek glasses Custom Direct Import Order Recalls – 2010, Wegman’s, an east coast supermarket recalls their 2009 holiday bags because of high lead content. Not a mandatory recall and not a safety concern, but publicity prompted Wegman’s to remove the bags and offer customers free replacements. 2010, McDonald’s recalls 12 million Shrek glasses. I don’t think the cadmium was above approved levels but still glasses were recalled. 2011, Build-A-Bear workshop recalls 26,500 lapel pins because of excessive lead levels in surface paints. 2011 Build-A-Bear lapel pins

How did we get here? When did product safety become my concern? Prop 65 (1986) - Goal was to protect drinking water. Established burden of proof was put on the business. Lead (2007) - Targeted ceramics & glassware BPA (2008) - Used in consumer plastics and has fallen out of favor and MOST drinkware products are now BPA free. CPSIA – Consumer Product Safety Improvement Act – focus is on protecting children. Here’s a history lesson WITH REGARD TO THE PROMOTIONAL PRODUCTS INDUSTRY Prop 65 passed in 1986. This California law seeks to protect citizens from chemicals known to cause cancer, birth defects or other reproductive harm. If the products you intend to distribute contain a chemical on the Prop 65 list, a warning statement is required to alert consumers of its presence. This is required for all products distributed in California—even if the rest of the supply chain is outside of the state. In 2007 Lead & cadmium hit the spotlight in the promotional products industry primarily because of Prop 65 and the law’s bounty hunter approach to violations. Ceramics and glassware were the initial targets. The reason, many of the inks used in decorating ceramics and glassware contained lead and or cadmium to give the decoration durability. Because California’s Prop 65 maximums were lower than the FDA’s, it put most coffee mug decorators in a precarious spot. The met FDA standards but were in violation of Prop 65. Since most non-Californian’s knew nothing about Prop it wasn’t an issue until the Prop 65 bounty hunters discovered our industry. Vernon’s bounty hunter story BPA has been used in consumer plastics since the early 1900’ s. In 2008 concerns starting becoming expressed about it’s use in food containers and possible negative side-effects on humans. The FDA has not banned it’s use but other organizations questioned it’s safety. It’s fallen out of favor and most drinkware products in the promotional products industry are BPA free.

What is the CPSIA? Consumer Product Safety Improvement Act In 2008, the CPSIA toughened up existing safety standards, especially for children’s products. Key components of the act include, lower maximums for lead and other toxic chemicals and a permanent tracking system for all products intended for children under the age of 12. However, an item that your organization doesn’t intend for children doesn’t exclude it from the CPSIA. CPSIA – In 2008, in response to numerous product recalls, Congress passed the Consumer Product Safety Improvement Act, toughening up existing safety standards, especially for children’s products. Key components of the act include, lower maximums for lead and other toxic chemicals and a permanent tracking system for all products intended for children under the age of 12. This act is complicated, confusing and has some interesting side effects including the banning of some small motorcycles and 4-wheelers because of the lead content of their paint. The focus is on protecting children.

What is the CPSIA? Example: A coffee mug (for adults) with a Dora The Explorer logo given to customers is considered an item targeted for children and must pass CPSIA standards. If not, it can land your organization in legal & financial trouble!

What is a Children’s Product? A consumer product designed or intended primarily for use by children 12 years of age or younger. Products intended for this group require compliance to stricter standards, tests, and product labeling.

Which one has the greatest product safety risk? It’s a complicated issue with many nuances. Here’s a little exercise to show you what I mean. Here are four common promotional advertising products. Which one poses the greatest compliance risk to your company?

Which one has the greatest risk? The truck.

Which one has the greatest risk? Here’s a second one. Which one poses the greatest risk to your company?

Which one has the greatest risk? The water bottle.

Why the truck and water bottle? While a knife might seem to be a greater safety risk, the toy truck is considered an item for children. Even if it’s intended to be a collector’s piece, destined for a car enthusiast’s mantle, it must go through the rigorous checks to pass the CPSIA. The Noah’s Ark Preschool imprint makes the water bottle a children’s product, and subject to CPSIA regulation. The point of these exercises is, it’s challenging to know the in’s and out’s of all the regulations and how they apply in each situation. I’m going to show you how you can protect yourself and what Vernon does to ensure you get safe compliant products.

Don’t Panic! Promotional marketing products are safe and effective for promoting your brand! Be aware of the safety issue Ask the right questions Use the right promotional products partner By this time you may be saying, I don’t want to mess with these! That would be a mistake. Promotional products are safe and effective.

Questions You Need To Ask What specific steps are you taking to ensure we received the safest products possible? How do you handle children’s products? Can you provide a GCC (General Conformity Certificate) for the products we order? How much liability insurance do you carry? You don’t have to be an expert in this area, your supplier should be. By asking a few simple questions, you’ll quickly find out if you should be working with that distributor or not. You need to know how they’re handling product safety and you should expect a quick, educated response You want to work with distributors that are financially stable and have the resources to handle your order and deal with any probems that come up. If the worst happens, you want to know your distributor is protecting themselves and you with indemnification and insurance.

Vernon Protects Your Brand Experience - in the same business for 110 years! Industry Top 40 Distributor Process over 60,000 orders each year Stability - Highest D&B rating, AAAA1, for over 20 years Work only with suppliers that can present sufficient documentation showing compliance with CPSIA

Vernon Protects Your Brand Custom importing Approved vendors Screening Testing and documentation Implemented supplier safety standards Supplier approval process GCC’s on file Test results on file Supplier indemnifications Vernon named as co-insured The custom import scene has been compared to the wild west. There are laws and regulations to protect everyone but enforcing those regulations can be a challenge. Some of the most high-tech, productive and safe factories in the world are in China. But some of the worst in the world are there also. How do you know which one you’re working with? There’s also a cultural difference that makes communication challenging and most of the time Chinese companies require a substantial down payment before they’ll work on your project. For these reasons we began our product safety initiative with custom importing and started by intentionally reducing the number of vendors we worked with. Each vendors had to provide documentation showing they had a product safety policy in place with the correct procedures to protect our clients. They also had to demonstrate the understood product safety regulations and testing requirements since many direct import orders need some type of testing before hitting the US. The also need a high quality and service rating within our industry. Direct importing is potentially where you have the great exposure and risk. Both with the product quality and your money. Be sure you’re working with someone with a track record. Ask the important safety questions Next we addressed our net work of preferred vendors for traditional, US decorated products. We worked jointly with other large companies in this industry to identify a set of documents and provisions that would provide the highest level of protection for our clients and their customers. No on can guarantee there will never be a problem but the chances of a problem occurring with one of our approved vendors is very, very low, and in the extremely unlikely event there would be a problem, we’ve protected you and your client.

Vernon Protects Your Brand Social Compliance No abuse of labor No child labor Hours and wages regulations Safe workplace conditions Abide by environmental laws & regulations Helped draft our industry association’s Code of Product Responsibility No Abuse Of Labor - We will not use any form of forced labor, including indentured, prison, bonded or slave labor. We will not use physical or verbal harassment or abuse to discipline employees. No Child Labor -We will not use child labor. We will comply with all minimum age provisions of applicable laws and regulations. Hours And Wages - We will comply with all applicable wage, work hours, benefits, and overtime laws and regulations. If local industry standards are higher than applicable laws and regulations, we will meet the higher standards. Workplace Conditions - We will provide a safe, healthy and secure workplace. We will abide by all applicable laws and regulations for safety and health. Proper sanitation, lighting, ventilation and fire safety protection will be provided. Environment - We abide by all applicable environmental laws and regulations. We will manage our environmental footprint to minimize the adverse impact on the environment. We will manage our energy, water and waste systems for maximum efficiency and minimal adverse impact on the environment. PPAI Code of Conduct – On our website http://www.vernoncompany.com/company/code-of-product-responsiblity-conduct/

Vernon Protects Your Brand We Promise To Protect Your Brand As If It Were Our Own We want to protect product recipients, our clients and their brand reputation, our account executives, as well as ourselves Product safety is the law, and it’s the right thing to do Safety is a top priority for Vernon

Resources PPAI: www.ppai.org Consumer Product Safety Commission: www.cpsc.gov ; www.recalls.gov American National Standards Institute: www.ansi.org or www.astm.org Specialized Technology Resources: www.STRQuality.com