Undue Influence

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154 E Aurora Rd

Northfield, OH 44067

The Marketing Group Undue Influence Policy

Policy

The Marketing Group is committed to complying with the Undue Influence requirements of theConsumer Product Safety Improvement Act [CPSIA] and the Final Rule on Testing andCertification of Children’s Products, issued by the Consumer Product Safety Commission. The Undue Influence requirements prohibit manufacturers from exercising undue influence on a third party conformity assessment body (i.e., a CPSC-accredited, third party testing laboratory). The Marketing Group will not tolerate any efforts to unduly influence third party conformity assessment bodies.

Procedure

Undue Influence Defined - Undue influence is any action taken by The Marketing Group personnel that could undermine the integrity of laboratory test data used in the certification of children’s products.

Training

All associates that interact with testing labs will be trained to safeguard against exercising undue influence on testing labs. If The Marketing Group makes any substantive changes to this policy, all associates that interact with testing labs will be retrained regarding those changes. All associates must sign a statement attesting to their attendance at the training.

Reporting

It is the responsibility of each associate to promptly report any incident of undue influence to Paula Teague, who is responsible for investigating undue influence reports.An associate is not required to report incidents of undue influence to Paula Teague if that person is the individual who is exercising undue influence, or if the associate would feel more comfortable reporting the incident(s) to his or her immediate supervisor or any other member of management. An associate may also confidentially report incidents of undue influence directly to the Consumer Product Safety Commission. The Consumer Product Safety Commission can be contacted at (800) 638-2772 or through http://www.cpsc.gov/cgibin/info.aspx. Supervisors or managers who receive reports of, or otherwise observe, incidents of undue influence should immediately inform Paula Teague or another appropriate Marketing Group official, so that an investigation may be initiated.

Investigation

Every reported incident of undue influence will be investigated thoroughly, promptly, and to the extent possible, in a confidential manner. The Marketing Group will not tolerate retaliation against any associate for reporting an incident or cooperating in an investigation of reported undue influence.

Corrective Action and Discipline

If undue influence is established, The Marketing Group will take corrective action. The Marketing Group will immediately report such findings to the Consumer Product Safety Commission. Corrective action may also include, for example, retesting of the product implicated, training, and/or disciplinary action ranging from verbal or written warnings up to and including termination of employment, depending upon the circumstances.