Policy for Online Advertising
Effective June 10, 2010

In order to protect the quality image of the products sold under the Polyconcept North America ("PCNA") brands Leed's, Bullet, and Journalbooks (each a "PCNA Company", and collectively the "PCNA Companies") as well as Leed's licensed brand names ("Leed's Licensed Brand(s)"), and to maintain consistency among all PCNA brands and Leed's Licensed Brands (collectively, the "Brands"), Leed's is reissuing its Policy for Online Advertising from June 1, 2009, and Bullet and Journalbooks are adopting this reissued policy (the "Policy"), such reissuance and adoption to be effective as of June 10, 2010.

For the purposes of this Policy, Leed's Licensed Brands include: Aladdin®, Alicia Klein®, Balmain®, California Innovations®, Case Logic®, Cutter & Buck®, Day-Timer®, Dockers®, Duracell®, Everlast®, Garrity®, High Sierra®, JournalBooks, Karim Rashid®, Laguiole®, Owl®, Scripto®, Slazenger®, Sourcery®, Sportline®, Stanley®, StrombergBrand®, Wenger®, and Zippo®. This Policy also extends to any new Leed's Licensed Brands as they may be introduced to the Leed's product line in the future. All other products in the Leed's product line are considered Leed's products.

The Policy is as follows:
1. The PCNA Companies will sell products only to those Distributors or qualified Resellers who, in the sole discretion of the PCNA Companies, do not diminish or otherwise harm any of the Brands. The following are examples of conduct that the PCNA Companies believe diminish the Brands:

a. advertising or marketing any of the Brands in any way that disparages, misrepresents or injures any Brand; and/or

b. advertising or marketing products through online or print advertising methods at deeply discounted prices (e.g., discounted more than 10% (for Leed's Licensed Brand products) or 20% (for any other PCNA Company's brand products)) from the applicable company's lowest published coded catalog prices; and/or

c. using any Brand products in any illegal, deceptive, undesirable, or improper advertising, marketing or selling practice, including predatory or "loss leader" pricing, bait and switch, or negative selling practices.

2. The Brand products are for sale only through the promotional products industry. They are not intended for sale through electronic retail channels (i.e. eBay, Amazon.com, etc.).
This Policy represents each PCNA Company's unilateral statement of its intent in selling, or continuing to sell, its respective products, and is not a contract for the sale of products, nor an offer to form a contract. The PCNA Companies are not asking for, and will not accept, any agreement about a Distributor's compliance with this Policy. Rather, this Policy reflects the PCNA Companies' decision on how to best to advertise and market their respective products, including the decision to sell to only those Distributors who are committed to furthering the Brands, and appropriate product positioning.

If a PCNA Company discovers a Distributor engaging in any practice inconsistent with this Policy, it may unilaterally decide, in its sole discretion, to terminate its business relationship with that Distributor in whole or in part. Each PCNA Company reserves the right, in its sole discretion, to choose those Distributors with whom it will do business for Brand products.
Except as specifically authorized by a PCNA Company, PCNA Company sales representatives are strictly prohibited from discussing this Policy or any advertising, pricing, or product positioning practice with any Distributor, and from seeking or accepting any assurance of compliance with this Policy. All questions regarding this Policy shall be directed, in writing, to adpolicy@polyconceptna.com



Polyconcept North America

400 Hunt Valley Road, New Kensington, PA 15068

Phone: 888 476 5962 Fax: 724 334 1256

www.polyconceptna.com



Subject: Policy for Online Advertising

The PCNA Companies do not seek any comments from any Distributor about the advertising, pricing, or product positioning practices of any other Distributor. Further, the PCNA Companies will not, under any circumstances, discuss the business dealings of any Distributor with any other Distributor. The PCNA Companies reserve the right to change, amend, or discontinue this Policy at any time.