Easy Comforts’s Environmental Policy & Vision Statement

Easy Comforts recognizes how vital it is to incorporate environmental stewardship in the conduct of business, including the efficient and sustainable use of natural and economic resources, which incorporates practices such as energy conservation and preservation of biodiversity. Easy Comforts is committed to understanding the impact our organization has on the environment and to continually improving our environmental performance, while encouraging our suppliers and customers to do the same.

To this end, we seek to adhere to principles addressing the following eight areas, and to support these principles through specific initiatives. Our goal as an organization is to address these key aspects of our environmental performance as members of the direct marketing community:

PRINCIPLE AREAS

• List Hygiene and Data Management
• Design
• Paper Procurement and Usage
• Printing and Packaging
• Recycling and Pollution Reduction in our Workplace and Community
• Internal and Supplier Code of Conduct
• Green Building
• Social & Community Outreach

INITIATIVES IN SUPPORT OF PRINCIPLE AREAS

I. LIST HYGIENE AND DATA MANAGEMENT

Easy Comforts continually endeavors to manage data and lists in an environmentally responsible manner with a focus on reducing the amount of duplicate, unwanted and undeliverable mail [to both consumers and businesses]. To achieve our goals in this area:

A. We Maintain Suppression Lists

• We maintain in-house do-not-market lists for prospects and customers who do not wish to receive future solicitations from us (required by DMA Privacy Promise).

B. We Offer Notice & Choice

• We provide periodic notices and opportunities for customers to opt in or opt out of receiving future marketing contacts from our organization (required by DMA Privacy Promise).
• We provide periodic notices and opportunities for prospects to opt in or opt out of receiving future marketing contacts from our organization.
• We offer customers a choice to receive communications from our organization electronically.

C. We Clean Our Lists Prior to Mailing

• In addition to use of the Direct Marketing Association (U.S.) Mail Preference Service (MPS) on all applicable consumer prospecting lists, we maintain clean, deliverable files by using:
• ZIP Code correction
• Address standardization
• USPS National Change of Address (NCOA)
• Other USPS products such as
• Address Element Correction (AEC),
• Delivery Sequence File (DSF),
• Address Correction Requested (ACR)
• Predictive models and RFM segmentation
• We use the DMA "Deceased Do Not Contact" list to eliminate names of deceased persons from mailings.

D. We Merge/Purge Our Data

• We match outside lists against each other to prevent duplicates.
• We use match definitions in merge/purge that minimize duplicates.
• We match outside lists against other commercially available suppression files where appropriate.

E. We Test Market Offers

• We test a sample of a list before mailing or marketing to the entire list.
• We test different versions of advertising and marketing offers, in mail and other media, to select those offers and media combinations that receive the best response.

II. DESIGN, PRODUCTION AND PRINTING IN OUR MAIL, MARKETING AND COMMUNICATION MATERIALS

Wherever feasible, in designing and printing communications, we look at opportunities for source reduction. We also communicate this goal to our suppliers. To this end:

A. We Reduce the Amount of Waste

• We review periodically direct mail and direct marketing packages and downsize when and where appropriate.
• We test and use lighter-weight papers wherever feasible.
• We adjust trim sizes of our publications and/or collateral in an effort to reduce waste.
• We test and use production methods that reduce print order overruns, waste allowances and in-process waste.

C. We Give Preference to Recyclable and/or Reusable Materials

• We routinely survey the marketplace for high recycled content for corrugated boxes and packing materials and/or recyclable or reusable materials.
• We seek to utilize recycled printing and writing paper with post-consumer content when and where feasible; and where measured environmental improvements occur.
• We ensure, where possible, that all packing and packaging materials are made of recyclable (collected locally throughout the country), recycled, reused or reusable materials.

D. We Communicate Environmental Principles to Suppliers

• We  require supplier companies to comply with all applicable laws and regulations in respect of protecting the environment

III. PAPER PROCUREMENT AND CLEAN PRODUCTION

Easy Comforts recognizes that improving forestry practices is an important component of environmental stewardship and sustainability. We strive to procure, use, and recover paper in a manner that helps to ensure the sustainable use of forests and other natural resources. In support of this principle:

A. We Research & Understand Our Investment in Paper

§  We work to understand the investment our company has in paper.

§  We invest time and resources to understand and address environmental issues associated with paper procurement.

§We strive to identify our "fiber supply chain" for forest products we use, such as paper for catalogs and other marketing materials, and corrugated packaging.

§  Our designated buyers have expertise in procuring environmentally preferable paper.

B. We Respect Forest Ecosystems and Biodiversity

• We require that our paper suppliers have made a commitment to implementing sustainable forestry practices that protect forest ecosystems and biodiversity as well as provide the wood and paper products our company needs.
• Wherever feasible we specify that paper suppliers use third-party, verified traceability or chain-of-custody so that we know the origin of fiber in our paper.
• We avoid paper from sources that are known to log unsustainably or illegally managed forests.
• We recognize the importance of maintaining biodiversity and will work with suppliers who have integrated conservation values and programs into their operations.

C. We Encourage Sustainable Paper Procurement and Clean Production

• Wherever feasible, we require paper suppliers to provide annual reports on their environmental practices.
• We give preference to paper suppliers which are certified and verified by an independent third party.
• Currently  our suppliers adhere to standards maintained by:
• CSA (Canadian Standards Association)
• FSC (Forest Stewardship Council)
• PEFC (Program for the Endorsement of Forest Certification)
• SFI (Sustainable Forestry Initiative)
• We give preference to suppliers who conform to International Organization for Standardization (ISO) 14001 environmental management standards for manufacturing and forestry practices.
• We give preference to suppliers which use loggers who have been properly trained in recommended harvesting and reforestation methods.
• We aim for continuous improvement in the percentage of certified wood fiber in our paper (in other words, fiber from third-party certified forests).

Easy Comforts

D. We Encourage Responsible Use of Forest Resources

• We evaluate paper used for marketing pieces and internal consumption to identify opportunities for increased post-consumer recycled content, lower basis weights and other environmental attributes.
• Whenever the economics are sound and the environmental benefits clear, we purchase paper with recycled content, including papers with post-consumer content
• We negotiate with our paper suppliers about purchasing papers with post-consumer recycled content at a comparable price, environmental impact and performance to virgin papers
• We print order forms, blow-ins and order envelopes on paper with a higher percentage of post-consumer recycled content whenever feasible.
• We reduce the amount of raw materials used to make our products by encouraging the development of lighter-weight grades of paper that meet our organization’s functional and quality needs.
• From 2005 to 2007 our use of lighter weight paper has reduced our total wood use by 1,472 tons, or 10,191 trees. The energy saved was 21,806 million BTU’s, enough to power 240 homes each year. Greenhouse gases were reduced the equivalent of 4,364,582 lbs CO2, or the emissions from 396 cars per year. Wastewater was reduced 10,219,474 gallons. Click here for more details.
• We work with our printers to reduce paper waste (reduced overage counts, make-readies, etc.).

IV. USE OF PAPER IN PACKAGING

Easy Comforts believes that sourcing environmentally preferred papers and other materials is only a beginning. Equally important is efficient use of papers and materials once they are purchased.

·         Our shipping containers contain over 60% post-consumer content.

·         We work continually to eliminate unnecessary packaging materials that do not protect merchandise or enhance its presentation before prospects and customers.

• We continually monitor the use of our packaging material to minimize usage yet provide adequate protection for our merchandise. In our fulfillment, we implement packaging guidelines that optimize the ratio between the size of outgoing shipments and the size of cartons used.
• In our fulfillment, we use reusable packaging that allows customers to return items in the same package used for shipping to ease the return process.
• We sort incoming packaging materials for recycling collection.
• We reuse incoming packaging materials for outgoing shipments where possible.
• We employ lighter-weight  packing materials where possible to minimize volume/weight and reduce our environmental footprint.

V. RECYCLING AND POLLUTION REDUCTION IN OUR WORKPLACE AND COMMUNITY

Easy Comforts’s policies and initiatives in this area are guided by the Three R’s: "Reduce, Reuse, and Recycle." With this in mind, we seek an efficient and environmentally sensible workplace, as well as to promote environmental stewardship in our community. Toward this principle,

A. We Reduce & Reuse in the Workplace

• Where possible and practical, we buy office papers, packing and packaging materials made from recycled materials with post-consumer content.
• Where practical we will use recyclable materials and materials that don’t hinder the recycling process.
• We integrate the use of electronic communications (e-mail, Web and intranet) for external and internal communications.
• We make primary use of two-sided printing and photocopying where appropriate.
• We develop online systems for reports, projects and monitoring to reduce paper generation.
• We reuse office supplies such as file folders, hanging folders and binders where appropriate.
• We substitute durable materials for disposable products where possible.

B. We Deploy Recycling in Our Workplace

• We implement in-house recycling programs for:
• Paper
• Corrugated cardboard
• Beverage cans and bottles
• Plastics
• Pallets
• Toner cartridges
• Personal and laptop computers. 3 year lease ensures most current energy conservation technology.
• We annually recycle 600 tons of cardboard, 60 tons of office paper, and 6 tons of other materials

• We participate in existing industry-specific or government programs for:
• Energy savings
• We have made recent lighting improvements at our distribution center that saves over 1,100,000 kwh of electricity annually. Click here for more detail.

 VI. INTERNAL AND SUPPLIER CODE OF CONDUCT

Easy Comforts is committed to enforcing an internal code of conduct that provides for a safe and fair working environment for its team members. We also recognize that it is this code of conduct that must be the basis for evaluating current and potential suppliers. Easy Comforts maintains the following codes and policies:

A. Equal Employment Opportunity

·         We support and have a strong commitment to equal opportunity.

·         We recruit, train, hire, transfer, promote, compensate, and make all employment related decisions without regard to an individual’s race, color, religion, age, sex, national origin or ancestry, marital status, physical or mental disability, sexual orientation, or any other protected status as required by law.

B. Safety and Health

·         We strive to make our workplace as safe and healthy as possible by meeting or exceeding all local, state, and federal (OSHA) workplace safety requirements.

·         We have established a workplace safety program monitored by our Facilities and Safety Leader and our Safety Committee.

·         We provide information to team members about workplace safety and health issues through regular departmental meeting, bulletin board postings, memos, “lunch & learn” programs, and other means.

·         We encourage feedback from our team members and use this information to make our workplace as safe and healthy as possible.

·         We aggressively investigate accidents or reports of code violations and make changes necessary to prevent future accidents or to correct violations.

·         Emergency procedures regarding chemical spills, first aid assistance, fire drills, and tornado drills are practiced routinely.

C. Harassment

·         We are committed to providing a work environment that is free from all forms of discrimination and conduct that could be considered harassing, coercive, or disruptive, including sexual or any other illegal harassment.

D. Supplier Code of Conduct

·         We seek to partner with suppliers that are committed to ethical conduct, meet the above requirements regarding equal opportunity, safety and health, and harassment as well as the following:

• Child Labor - Suppliers shall not use child labor.  “Child” is defined as a person who is not older than the local age for completing compulsory education but in no event is less than 15 years of age.  Suppliers must verify the age of their workers and maintain copies of their workers’ proof of age.  Suppliers must follow all applicable laws and regulations regarding working hours and conditions for minors
• Involuntary Labor - Supplier shall not use involuntary labor.  “Involuntary Labor” is defined as work or service which is extracted from any person under threat or penalty for its non-performance and for which the worker does not offer himself or herself voluntarily, and includes all manner of prison, bonded, indentured and forced labor.
• Disciplinary Practices - Suppliers shall not use corporal punishment or any other form of physical or psychological coercion or intimidation against workers.
• Non-discrimination - Suppliers shall employ workers solely on the basis of their ability to do the job, and shall not discriminate on the basis of age, gender, racial characteristics, maternity or marital status, nationality or cultural, religious or personal beliefs or otherwise in relation to hiring, wages, benefits, termination or retirement.
• Health and Safety - Suppliers shall maintain a clean, safe and healthy workplace in compliance with all applicable laws and regulations.  Suppliers shall ensure that workers have access to clean drinking water, sanitary washing facilities and an adequate number of toilets, fire-extinguishers, and fire exits and that workplaces provide adequate lighting and ventilation.  Suppliers shall ensure that the aforementioned standards are also met in any canteen and/or dormitory which is provided for workers.
• Environmental Protection - Suppliers shall comply with all applicable laws and regulations in respect of protecting the environment and maintain procedures for notifying local authorities in the event of an environmental accident resulting from Suppliers’ operations.
• Wages and Benefits - Suppliers shall provide wages and benefits that comply with all applicable laws and regulations or match the prevailing local manufacturing or industry rates, whichever is higher.  Overtime pay shall be calculated at the legally required rate, regardless of whether workers are compensated hourly or by piece rate.
• Working Hours - Suppliers shall not require workers to work, including overtime, more than 60 hours per week or more than any maximum number of hours per week established by applicable laws and regulations, whichever is less.  Suppliers shall guarantee that workers receive at least one day off during each seven-day period.
• Freedom of Association - Suppliers shall respect the right of workers to associate, organize and bargain collectively in a legal and peaceful manner.
• Familiarization and Display of This Code of Conduct - Suppliers shall familiarize workers with this Code of Conduct and display this Code of Conduct, translated in the local language, at each of their facilities in a place readily visible and accessible to workers.
• Legal Requirements - Suppliers shall comply with all legal requirements applicable to the conduct of their businesses, including those set out above.
• Contractors and Suppliers - Suppliers shall ensure that their contractors and suppliers adhere to this Code of Conduct.
• Monitoring of Compliance - Suppliers authorize Walter Drake and its principals to conduct scheduled and unscheduled inspections of Suppliers’ facilities for the purpose of ensuring compliance with this Code of Conduct. During these inspections, Easy Comforts and its principals shall have the right to review all employee-related books and records maintained by Suppliers and to interview workers.
• Corrective Action - When violations are found, Walter Drake and the Supplier concerned will agree on a corrective action plan that eliminates the problem in a timely manner.  If it is determined that a Supplier is knowingly and/or repeatedly in violation of this Code of Conduct, Easy Comforts and its principals shall take appropriate corrective action, which may include cancellation of orders and/or termination of business with the Supplier in question.

VII. GREEN BUILDING

Easy Comforts Company participates in Wisconsin Focus on Energy program for training and assistance in energy conservation projects. These Green Building initiatives include best practices in Lighting, HVAC and Air Compressors operations to reduce operating costs and conserve energy.  Easy Comforts will consider LEED (leadership in energy and environmental design) guidelines in maintaining the building and future building projects.

·         We made recent lighting improvements at our distribution center that will save over 1,100,000 KWH of electricity annually. This is the equivalent of 2,640,000 lbs. of CO2 not introduced into the environment, or 2,162 barrels of oil not burned.

·         We strive to substitute current products and services for environmentally preferred products and services whenever they perform satisfactorily and are available at reasonable prices.

·         Our contracted janitorial service uses environmentally friendly Green Cleaning supplies, equipment, and methods to improve indoor air quality that translates into a healthy working environment for employees and visitors.

·         Only Green Seal certified carpet chemical and cleaning equipment is used which meets Carpet & Rug Institute Green Label Program Requirements.

VIII. SOCIAL & COMMUNITY OUTREACH

Easy Comforts is a socially responsive company with a strong history of giving in the community. We encourage our team members to give of their time and money whenever possible. Recent efforts by the team members include:

·         Easy Comforts team members donate to the United Way with automatic payroll deductions.

·         Participation in and donations to the local Walk to Cure Diabetes sponsored by Juvenile Diabetes Research Foundation

·         Participation in and donations to the local annual Heart Walk sponsored by the American Heart Association

·         Hosted 4 company blood drives during the last 12 months

·         Donations to American Red Cross hurricane Katrina disaster fund

Easy Comforts is committed to continually improve our environmental performance. We endeavor to make responsible, sound business decisions and wherever feasible integrate environmental considerations into all aspects of our operations. We readily acknowledge that environmental stewardship is an ongoing challenge and a continual learning experience. We continue to research best practices and to explore the possibility of partnerships with other companies, environmental and conservation organizations, and local communities, all with the intent of further strengthening our environmental stewardship.