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PRIMARK MANUFACTURING RESTRICTED SUBSTANCES LIST (MRSL) GUIDELINES

1.0 PURPOSE
All suppliers of Primark product are required to meet the ZDHC MRSL requirements.

The purpose of the Primark MRSL Guidelines (this document) is to:

Provide guidance for suppliers to meet the ZDHC MRSL requirements

Detail minimum requirements for chemical management

2.0 SCOPE
The requirements detailed in the ZDHC MRSL and this document applies to all upstream supply chain
stakeholders including:

Finished product suppliers e.g. jacket

Raw material suppliers e.g. fabric

Chemical product suppliers e.g. dyeing products

Service providing sub-contractors e.g. printing

3.0 PROCESS

3.1 STEP 1 COMMITMENT


Suppliers shall understand and commit to the Primark commitment to the ZDHC MRSL.

The Supplier Chemical Management Policy included in Appendix 1 shall be completed by the supplier
and all upstream supply chain stakeholders as detailed above.

One person must be nominated in the Policy responsible for chemical management in the factory.

Suppliers shall return the signed commitment to environmental@primark.co.uk

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3.2 STEP 2 - MANAGEMENT
Suppliers shall maintain a list of all upstream suppliers of product and services associated with Primark
production.

The ZDHC MRSL and Primark MRSL Guidelines shall be communicated to all upstream suppliers and
details recorded using the format provided in Appendix 2.

Suppliers shall maintain a list of chemical formulations used in all manufacturing processes associated
with Primark production using the format provided in Appendix 3.

It is the suppliers responsibility to obtain MRSL compliant documentation i.e. positive lists from
chemical suppliers and incoming formulation testing on a due diligence basis to ensure compliance.

The responsible Chemical Manager shall maintain a Chemical Management System that includes at a
minimum:

A Chemical Management Policy (Appendix 1)


A process to procure products from suppliers who are ZDHC MRSL compliant
A process to ensure sub-contracted services are ZDHC MRSL compliant
The maintenance of a chemical inventory (Appendix 3)

Suppliers are expected to implement ongoing training and education to employees and upstream
suppliers to communicate these requirements and support implementation.

3.3 STEP 3 MONITOR & REVIEW


Suppliers shall monitor and review ZDHC MRSL conformance on a due diligence basis.

This review must include at a minimum:

Evaluation of the Chemical Management System


Testing of incoming products against the ZDHC MRSL
Ongoing assessment of chemical management performance

Suppliers shall use Appendix 4 to assess own and upstream supplier conformance.

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APPENDIX 1 SUPPLIER CHEMICAL MANAGEMENT POLICY

Supplier: [COMPANY NAME]

Location: [COUNTRY]

Date: [XX/XX/XXXX]

[COMPANY NAME] are committed to the elimination of hazardous chemicals in all


manufacturing processes associated with Primark production.

We commit to the ZDHC MRSL requirements and implementation of the Primark MRSL
Guidance Document.

This commitment extends to all upstream suppliers of products and services associated with
Primark production.

The representative for the ownership of this policy and chemical management in this
organisation is as follows:

Chemical Manager: [FULL NAME]

Contact: [EMAIL]

We believe in the importance of eliminating these chemicals for the health of our employees,
the environment and the public.

Signed:

PRINT NAME___________________________POSITION_____________________________________________

Date:

______________________________________________________________________________________

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APPENDIX 2 RECORD OF UPSTREAM SUPPLIER ENGAGEMENT

SUPPLIER & PRODUCT/SERVICE MRSL & CHEMICAL POLICY TESTING PLANNED


CHEMICAL GUIDELINES RECIEVED
MANAGER COMMUNICATED
e.g. SHIRTS Ltd e.g. shirts e.g. Yes e.g. Yes e.g. Yes

China 01.01.16 01.02.16 Shirts

Mr Smith 01.03.16

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APPENDIX 3 CHEMICAL INVENTORY FORMAT

CHEMICAL INVENTORY MINIMUM REQUIREMENTS

Formulator (Product) Name

Formulator Address

(including production location)

Formulation Name

CAS Number

(if applicable)

Invoice Reference

Delivery Date

Net Unit

(unit measure)

Safety Data Sheet (MSDS)

MRSL Compliant conformation

Certification Type

(if applicable)

Shelf Life

Intended Use Category

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APPENDIX 4 CHEMICAL MANAGEMENT CHECKLIST

CHEMICAL MANAGEMENT CHECKLIST


SUPPLIER: DATE:
YES/NO EVIDENCE
1. COMMITMENT
1.1 Received and understand Primarks commitment to the
elimination of hazardous chemicals
1.2 Received and understand the ZDHC MRSL
1.3 Signed Chemical Management Policy
(Appendix 1 of Primark MRSL Guidelines)
2. MANAGEMENT
2.1 Responsible Chemical Manager nominated Provide Contact
2.2 List of upstream suppliers and subcontractors associated
with Primark production
2.3 ZDHC MRSL and Primark MRSL Guidelines communicated
to all upstream suppliers and subcontractors
2.4 List of chemical products used for Primark production
(inventory as per Appendix 3 of MRSL Guidelines)
2.5 Chemical Management System
2.6 Training to employees on MRSL and guidelines
2.7 Training to upstream suppliers on MRSL and guidelines
3. MONITOR AND REVIEW
3.1 Testing of incoming products for MRSL compliance
3.2 Screening of chemical inventory for MRSL compliance
3.3 Assessment of subcontractors for implementation
(using this checklist)
3.4 Process to identify and replace any non-compliant
products and suppliers
4. ACHIEVEMENTS
4.1 Eliminated the use of APEOs in Primark production
4.2 Eliminated the use of Phthalates in Primark production
4.3 Eliminated the use of PFCs in Primark production

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