Registry No. 911— 1— It NATIONAL RECOVERY ADMINISTRATION PROPOSED CODE OF FAIR COMPETITION FOR THE RETAIL FUR MANUFACTURING INDUSTRY AS SUBMITTED ON SEPTEMBER 1, 1933 The Code for the Retail Fur Manufacturing Industry in its present form merely reflects the proposal of the above-mentioned industry, and none of the provisions contained therein are to be regarded as having received the approval of the National Recovery Administration as applying to this industry UNITED STATES GOVERNMENT PRINTING OFFICE WASHINGTON : 1933 For sale by the Superintendent of Documents, Washington, D.C, Price 5 Submitted by THE RETAIL MANUFACTURING FURRIERS OF AMERICA, INC. in) NATIONAL RETAIL MANUFACTURING FUR CODE OF FAIR COMPETITION PURPOSE To effectuate the policy of Title I of the National Industrial Act, during the period of the emergency, by reducing and relieving un- employment, improving the standards of labor, eliminating competi- tive practices destructive to the interests of the public, employees, and employers and otherwise rehabilitating the Retail Fur Industry and in other respects, the following provisions are established as a code of fair competition for the entire Retail Fur Manufacturing Industry of the United States. Article I — Effective Date This Code shall become effective ten days after it has been approved by the President pursuant to the National Industrial Recovery Act. Article II — Definition of Terms (a) Manufacturing Furriers. — The term "manufacturing furriers" when used in this Code is defined to mean, and shall include, fur establishments employing labor in the manufacture of fur garments, fur pieces, or fur sets for use wholly or in part as wearing apparel. (b) Retail Manufacturing Furrier. — The term "retail manufacturing furrier" or "employer" when used in this Code is defined to mean, and shall include, any establishment, person, partnership, association, or corporation employing labor, engaged in the manufacture, servicing, production, cleaning, storing, repairing, or remodeling of fur coats, fur scarfs, or fur trimmings, and kindred articles made from furs and skins, and in making fur apparel for ready-made sale direct to the public, to order, or special measure. (c) Wholesale Manufacturing Furrier. — The term "wholesale manu- facturing furrier" when used in this Code is defined to mean and shall include any establishment or person employing labor in the manu- facture of wearing apparel made principally of fur and intended for resale as ready-made merchandise. (d) Fur Trimming Manufacturer. — The term "fur trimming manu- facturer" when used in this Code is defined to mean and shall include any establishment or person employing labor in manufacturing fur parts such as collars, capes, yokes, sleeves, cuffs, linings, borders, bands, intended for use as trimming upon garments of materials other than furs, whether such trimming items are to be sold to the men's or women's cloth and silk wearing apparel trades or to stores for direct sale to the public. (e) The term "worker" as used herein, is defined to mean one who is engaged in cutting, operating, nailing, finishing, squaring, taping, or staying of any garments made out of furs and skins and kindred articles in the Fur Industry. 9153—33 ( 1 ) (f) The term "nonmanufacturing employee" as used herein, is defined to mean all persons engaged in the Retail Fur Manufacturing Industry not included in any of the above classifications. (g) The term "Retail fur manufacturer" as used herein, is defined to include the retail fur manufacturer, the fur departments of depart- ment stores and specialty shops, the repairing, the remodeling, and/or cleaning of fur coats, fur scarfs, fur trimmings and any wearing apparel made out of furs and skins, direct to the consumer public or special order. Article III — Maximum Hours of Work Section 1. No employers in the Retail Fur Manufacturing Indus- try, as defined throughout the United States, shall operate on a schedule of hours of labor for their employees in excess of forty (40) hours per week, during the months of April, May, September, Octo- ber, November, and December, and thirty-five (35) hours per week during the months of January, February, March, June, July, and August. Recognizing the fact that the retail fur establishments in some sections have different seasonable peaks of employment and of production, we request of the Federal Administrator that if possible an option may be allowed of changing the above months, but not the number of months, on each hourly basis. Sec. 2. The regular working hours during the months when Forty (40) hours shall be the maximum hours of work per week shall be from 8 A.M. to 12 M. and from 1 P.M. to 5 P.M., on the first five working days of the week. Sec. 3. The regular working hours during the months when thirty- five (35) hours shall be the maximum hours of work per week shall be from 8:30 A.M. to 12 M. and from 1 P.M. to 4:30 P.M., on the first five working days of the week. Sec 4. No production work shall be permitted on Saturday or Sunday of any week, exception to be allowed towards working a small emergency group of employees on Saturday, providing that the total number of hours during the week of those employees shall not be over the maximums set forth above, provided, however, that if any firm or individual wishes to work on Saturday and not work on Monday that same shall be permitted. Sec 5. Overtime work is expressly prohibited save in cases of ex- treme emergency and then only, if satisfactory, other- than-regular employees cannot be secured, either or both from the Union or other- wise. In any case, such overtime should not be for more than the emergency purpose of finishing special and particular orders. When and where this emergency exists and overtime is granted, the num- ber of additional hours shall not exceed 8 hours per week. Sec 6. No person or persons under the age of sixteen (16) shall be employed in the manufacture or production of fur garments or fur articles. Sec 7. Employers shall not be permitted to manufactui j or pro- duce any fur garments or fur articles, under conditions that are known as "inside contracting", by giving a contract to workers in their respective factories for the production of same by the employees. Sec 8. No employers or employees shall be permitted to take out work to be performed at the homes of the employees or employers. Sec. 9. Employers shall not be permitted to give out work under a contract with workers for the finishing and lining of garments. Sec. 10. No manufacturing employee shall be permitted to work for more than one employer at one time or shall he or she be permitted to work in the aggregate in excess of the maximum number of hours, in a single week, as established in this Code, except where an emer- gency arises and a shortage of labor is definitely established. This to apply only during the forty (40) hour week periods and with the sanction and upon approval of the National Emergency Control Board of the Retail Manufacturing Furriers Inc., composed of re- sponsible impartial furriers, together with a representative of the Administrator of the Industrial Recovery Administration, or such agency as he may designate. Under these conditions labor is to be paid upon the basis of time and a half overtime. Sec 11. The labor conditions herein set forth shall also apply to all retail manufacturers who do not employ workers but perform the work themselves without the aid and assistance of craftsmen workers in the Industry and the maximum working hours established in this Code shall bind and be applicable to all employers and workers alike engaged in the production, manufacture, remodeling or repairing of fur garments and articles made from furs and skins. Not more than two members of a firm shall be permitted to actually perform work in the production of fur garments that are customarily and necessarily performed by the various craftsmen of the industry. Sec 12. For all other employees save supervisor employees, ad- ministrative employees, executives, and retail sales people, the maxi- mum hours of work shall not be in excess of forty (40) hours per week. Retail sales people shall not work on a schedule in excess of forty-four (44) hours per week, exception thereof, only when and where a scarcity of selling force is established. Peculiar to the fur industry, retail sales people are usually individually sought after by their own respective following among the public. Furs, in the main, are purchased in confidence and the public prefers being waited on by their own sales people, and it would to a great extent handicap both the employee, who in most instances is working in a large part on a commission basis, and also the employer if the sales persons were not available during the major business hours of the day. Article IV — Compensation Section 1. The minimum wage scale to be paid in the Metropoli- tan Area of New York shall be as follows: Minimum Rate Cutters: per hour First class $1. 42 Second class 1. 25 Operators: First class 1. 19 Second class 1. 00 Nailers: First class 1. 13 Second class . 94 Finishers: First class 1. 10 Second class . 88 Throughout the history of the Fur Industry, geographical wage differentials have existed, due in the main to the difference in living cost and general economic conditions and the ability adequately to manage the industries in the respective localities. The establish- ments in the Fur Industry in the different localities have been devel- oped under such differences in wages, and after a survey bearing on such differences in the various sections of the United States, it is pro- posed that a schedule of compensation be rated in accord with an agreement or to be computed upon the conditions set forth. Sec. 2. The wage scales in all other sections of the country shall be in such ratio to the scale fixed in the Metropolitan Area as the standard of living of the respective sections varies from the living scale in the Metropolitan Area, but should not in any case be below minimum scales prevailing during 1929. Sec. 3. The second class of cutters, operators, and nailers shall comprise those working on fur coats, robes, and other articles made from the following skins, namely: Angora, Astrakhan (common), Buffalo, Coneys, Dog, Hamster, Horse, Jackal, Kangaroo, Llama, Lion, Mice, Mufflon, American Opossum, Rabbit (all types), Sheep, Swan, Thibet, Wombat, and Zebra. Sec. 4. The second group of cutters shall include squarers. The second group of finishers shall include tapers and stayers on any kind of garment. Sec. 5. No piece work shall be permitted. Sec 6. No worker shall be employed below the minimum wage scales as herein established, except in cases of wages to be paid to the feeble, the old, and the ] earner, which shall be governed by mutual agreement. Employees may not collectively, however, bargain over and above the minimum wage scale, as herein established. All wages to be paid over and above the minimum wage scale shall be by agree- ment between the employer and the individual worker. Sec 7. The minimum wage scale that shall be paid by employers to any of their nonmanufacturing employees, shall not be less than $15 per week in any city of over 500,000 population, or in the imme- diate trade area of such city; nor less than $14.50 per week in any city of between 250,000 and 500,000 population, or in the immediate trade area of such city; nor less than $14 per week in any city between 2,500 and 250,000 population, or in the immediate trade area of such city; and in towns of less than 2,500 population to increase all wages by not less than 20 percent, provided that this shall not require wages in excess of $12 per week. Population for the purposes of this Code shall be determined by reference to the 1930 U.S. Census. Article V — Unemployment Insurance There is every hope and expectation on the part of employers and employees that through the National Industrial Recovery Act, steps will be taken to put into active operation an unemployment insur- ance fund. Accordingly, such fund will be undertaken, as soon as the enforcement of union labor standards and general stabilization have reached the point at which the provisions for payment of unemploy- ment contributions can be generally enforced throughout the entire retail fur industry. The time when the conditions in the industry have reached the point when such fund may be established shall be determined by the Committee of the National Emergency Control Board, hereinafter mentioned, and the Trade Administrator. When it is established, it shall be in accordance with such provisions as shall be determined by the said Committee and the Trade Adminis- trator, and not in conflict with any previous insurance enacted by any State Agency. Article VI — Classification of Retail Manufacturing Section 1. Retail Fur Establishments or Retail Furriers. — The name of "furrier" or "fur shop" is to be used only by firms employing labor in producing furs and fur garments, whereas exclusive sellers of ready-made fur merchandise shall not be permitted to call them- selves "furriers" or "fur shops", since the term "furrier" or "fur shop" implies a fur work shop and practical, mechanical skill in executing all manner of fur work. A bona fide practical furrier who has a shop but employes no labor, shall have right to call himself "furrier", or his establishment a "fur shop" upon approval of the National Emergency Control Board of the Retail Manufacturing Furriers of America, Inc., composed of responsible, impartial furriers together with a representative of the Administrator of the Industrial Recovery Act or such agency as he may designate. This is to protect the small, legitimate retail manufacturing furrier who is a practical fur craftsman, although employing no labor. trade practices Section 1. It shall be unfair competition for any one to sell or service furs at retail under false pretences of any sort, especially under the guise or impression that the public purchases such gar- ments or services at a wholesale price; that garments are sold as used samples at a sacrifice, or that the price of such garments or services is lower than that of other retail manufacturing fur establishments because the public buys from the maker or manufacturer, when every retail furrier is in fact in large part his own manufacturer. All such claims, if wholly or in part fictitious or misrepresentative, shall be deemed unfair competition. Sec 2. It shall be unfair competition for any one to sell or service furs or to advertise fur merchandise or services at retail at less than net cost plus 10% to insure that labor shall at least be partially cov- ered and protected. Excepted from this rule shall be seasonal clear- ance sales, and the sales of actually shopworn or damaged goods which must, however, be plainly marked as such, and which may be sold below actual production costs, but not more than 25% below current replacement values. Sec 3. Advertising statements (written, printed, radio, or display) which misrepresent merchandise, values, services, or which use false or misleading fur names; selling methods which tend to mislead the consumer in any manner, shall be deemed acts of unfair competition. Sec 4. Retail furriers shall be free to advertise their own goods, services, and prices, but reference to the goods, services, or prices of competing retail fur establishments shall be regarded as an act of unfair competition. This shall also apply to any written, advertised, or broadcast statements which lay claim to a policy of underselling competitors. 6 Sec. 5. Installment plan. — No retail fur establishment shall sell furs upon the installment plan, unless a carrying charge of at least 10% be added to the purchase price of such merchandise. Any contra- vention of this rule shall constitute an act of unfair competition. This, however, is not to apply to legitimate charge account trans- actions. Sec. 6. Storage. — No person, firm, or corporation shall receive fur garments for storage unless, first, that it be a fully qualified fur estab- lishment and that at least one first-class, practical craftsman shall be in charge and oversee the handling of such storage. Second, that proper facilities shall be maintained for careful and efficient handling of all garments and that a suitable fur storage room shall be available that will properly protect all garments from moth, filth, and vermin, and that it shall be deemed an act of unfair competition to advertsie cold storage in connection with storage unless such furs are actually placed in storage to hold the garments and subject them to frigid air. Nothing herein shall prevent a practical furrier or fur shop from receiving storage and caring for it in the ordinary manner. Sec. 7. Insurance. — Likewise it shall be an act of unfair competition to solicit and accept furs for storage unless proper and complete insurance protection accompanies the service. Sec. 8. Minimum charge for storage of fur garments shall be 2% of a fair valuation thereof, and, in any event, not less than $3. Small articles made of fur shall not be stored for less than 2% of a fair valuation thereof, and in any event, not less than $1. It shall be deemed unfair competition to make charges for Fur Storage which are not consistent herewith. Exception to be made when such furs are purchased during the period of nonutilization, and not to exceed fiscal year. Sec 9. Fur cleaning and servicing. — It shall be deemed unfair competition for any person outside of a furrier or a fur shop or one employing a fully skilled first class fur cutter working on the premises to accept fur garments of any sort for cleaning or servicing. It is to be considered that this part of the fur work is as essential to the pro- tection of the public as any other phase of the fur business and that an inefficient person handling fur garments in this connection is liable to do irreparable damage and the public should, therefore, be protected from such intruders. Also that no fur garments so accepted for cleaning or servicing shall be subjected to any other method except as those recommended by legitimate retail furriers as efficient and conservant. Sec. 10. Cleaning advertising. — Must specify whether furrier's method of dry cleaning methods are used. Sec 11. Trade-ins. — Trade-in allowances must not be advertised. Sec 12. Trade-in allowances. — Allowances on old fur coats must not exceed the actual value of such old furs for repair purposes. Sec 13. Free storage and alterations. — The advertising of free storage and free alterations of fur garments shall be regarded as an act of unfair competition. Sec 14. Trade names. — Trade names convey nothing to the general public and their use in describing similated furs must be qualified in parenthesis immediately following the article name and are not to be described with astericks requiring a search to determine what it means. Sec. 15. Guarantee. — Fur garments are made of skins of animals and any guarantee in relation to their wear is hazardous. When an article is guaranteed such guarantee must be definite and clear and specific as to the length of time; any qualification or reservation in reference thereto must be mentioned. Sec. 16. Cleaning and glazing. — When the merchants contracts or offers and is paid for the cleaning and glazing of the garment, such service must be performed in the recognized method of such treatment. Merely blowing the garment out with air does not constitute cleaning and glazing. Sec. 17. Selling by true names. — All furs sold to the consumer public by anyone are to be sold and billed under their true names, specifying whether natural, dyed, blended, or feathered. Any excep- tion shall be deemed an unfair business practice. Sec. 18. Bidding jor employees. — It shall be unfair practice to entice or wean away employees "manufacturing and/or nonmanufac- turing" from competitors or anyone in the fur industry to employ or seek to employ any employee who is employed in any division of the industry. Sec. 19. Limitation on sales. — A limitation on the number of sales to be held during the year shall be determined by mutual agreement with local Trade Rules. Sec. 20. Style copy. — It shall be considered unfair competition to copy styles and pirate designs of other retail manufacturers or stylists, and sell the same under the misrepresentation that it is the true design of the retail manufacturer. Sec. 21. Replacement Value. — The cost of production shall be derived at by a proper accounting system and calculating the actual cost of all materials used in the garment manufactured, plus cost of labor, plus overhead and incidental expense incurred in the mainte- nance of the business of the retail manufacturer. Sec. 22. Accounting. — It shall be incumbent upon all retail manu- facturers to keep and maintain accurate calculation and accounting books which shall be at all times available for inspection by the duly constituted representatives of the National Industrial Recovery Act. Sec. 23. Business Information. — Procuring or divulging otherwise than with the consent of the concern, information concerning the business of such concern, which is properly regarded as a business secret, or of confidential origin, shall be deemed an act of unfair competition. Sec. 24. Materials. — Selling, using, or substituting any material or materials inferior to the quality shown or specified, by the seller to the purchaser, or inferior method of manufacturing, not consistent with legitimate retail furriers' method, shall be deemed an act of unfair competition. Sec. 25. Misleading Information. —Disseminating, publishing, or circulating any false or misleading information relative to competitive merchandise or the credit standing or ability of any retail competitor, shall be deemed acts of unfair competition. Sec. 26. Gratuities. — Making or promising to any purchaser, or prospective purchaser, of any article or articles of fur, or to any officer, employee, purchasing agent, or representative of any such purchaser, or such prospective purchaser, any bribe, gratuity, gift, or other payment of any remuneration, directly or indirectly, shall be deemed acts of unfair competition. Article VII — Administration of the Code To further effectuate the policies of this Act and the policies of this industry, throughout the United States, it will be incumbent upon the Retail Manufacturing Furriers of America, Inc., to create and maintain a Committee, known as the National Emergency Control Board, consisting of adequate representation, which will include representatives of labor, retail manufacturers, fur departments of department stores, specialty shops, and any and all other retail fur outlets that are governed under the classifications of Article II of this Code, and shall include proper representation for divisional, sectional, and territorial classifications throughout the United States. This Committee shall operate and function under the jurisdiction of the Fur Trade Administrator or any Governmental appointee. Similar representation upon this National Emergency Control Board shall be given to any and all other retail trade associations throughout the United States as shall hereafter be formed and who shall participate and join in the observance of the provision of this Code. This Board shall be national in scope, functioning for the benefit of all those who are identified with, or directly interested, in the Retail Fur Industry, such as employ labor and are representative of the Retail Fur Industry, who they represent. This Board shall, in addition to other powers herein specifically conferred, be designated as a planning fair practice and controlling agency for the Retail Fur Industry. Such agency may, from time to time, present to the Federal Adminis- trator of this Act, recommendations based upon conditions in the Industry, as they may develop from time to time, which will tend to effectuate the operation of the provisions of this Code and the policy of the National Industrial Recovery Act. (a) Recommendation as to the requirements of such other and further reports from persons engaged in the Retail Fur Industry throughout the United States. All and any statistical information and the maintaining of uniform accounts as may be required to secure the proper observance of this Code, both in setting up of a Service Bureau for engineering, accounting, stabilization of industrial employment and compensation consistent with sectional standards of living, for the making of additional trade rules as to practices, methods, and conditions of trading, the naming and reporting of prices, to prevent and elrminate unfair competitive prices and practices and any and all other purposes that will secure and promote sound stable conditions in the Retail Fur Manufacturing Industry, in cooperation with this National Emergency Control Board. When such recommendations are made by this Control Board with the approval of the Trade Administrator, same will have the same force and effect as any other provisions of this Code. Such agency must at all times cooperate with the Trade Administrator in making any and all investigations as to the changing and observance of any of the provisions of this Code at its own instance or upon complaint of any one of the members of the Board. The said National Emergency Control Board shall investigate the matter or matters complained of and report its findings to the Administrator for appropriate disposition. (b) It shall be the duty of the National Emergency Control Board to investigate and report their findings of any laxity relative to the evasion of the Fur Manufacturers' Excise Tax. Sec. 2. There shall be a Secretary who will act under the Code. Under the direction of the Trade Administrator and/or the National Emergency Control Board, he will keep all books (except books of account) and records under the Code and, except as such National Emergency Control Board and/or Administrator shall otherwise provide, shall collect, file and collate all statistics and other informa- tion required by the National Emergency Control Board for the proper administration of the Code. Sec. 3. There shall be a Treasurer who will act under the Code and under the direction of the Administrator and/or the National Emergency Control Board. He will have custody of, and have charge of the disposition of, all funds collected under the Code; and he shall keep proper books of account showing the collection and disposition thereof. Sec. 4. The National Emergency Control Board and/or the Administrator shall have power from time to time to appoint and remove, and to fix the compensation of, all such other officers and employees and all such accountants, attorneys, and experts, as said Board shall deem necessary or proper for the purpose of administering the Code and to fix the compensation of the Secretary and the Treas- urer for their services in acting under the Code. Sec. 5. The expense of administering the Code shall be borne by the members and nonmembers thereof. The Trade Administrator and the National Emergency Control Board may from time to time make such assessments on Account of such expenses against the members and nonmembers of the Code as it shall deem proper and such assess- ments shall be payable as such Control Board and/or Trade Adminis- trator shall specify. Failure of any member or nonmember of the Code to pay the amount of any assessments against such member or nonmember for a period of thirty days after the date on which it became payable shall constitute a violation of the Code. Sec. 6. The National Emergency Control Board and/or Trade Administrator may from time to time appoint such committees as it shall deem necessary or proper to effectuate the purpose of the Code, he or they may delegate to any such committee generally or in particu- lar instances such of the powers and duties under the National Control Board under the Code, as such duties shall be deemed necessary or proper in order to effectuate such purpose. An}?- member of any such committee may be a member of the Code, as the Trade Administrator and/or Control Board shall deem proper. Sec. 7. None of the members of the Code shall be liable in any manner to anyone for any act of any other member of the Fur Industry or for any member of the National Emergency Control Board, or any committee, officer, or employee appointed under the Code, nor the Treasurer, nor the Secretary, nor any officer or employee appointed under the Code, shall be liable to anyone for any action or omission to act under the Code, except for his willful violation of duty or nonduty. Sec. 8. The National Emergency Control Board shall continue in effect for a period of not less than 90 days after the termination of the National Industrial Recovery Act, or any time after the expiration of such period as conditions may warrant. When so terminated, all obligations and liabilities under the Code shall cease, except those for unpaid assessments theretofore made in accordance with the pro- 10 visions of the Trade Administrator and/or National Emergency Con- trol Board and those for liquidated obligations theretofore accrued by the Trade Administrator and/or the National Emergency Control Board. Article VIII — Participation Any employer may participate in this Code and in any of the revi- sions of, additions thereto, and receive the benefits thereof, by accept- ing the proper pro-rata share of the cost and responsibility of creating and administering it, either by becoming a member of the applicants submitting this Code, or any association that may hereafter become parties to this Code, or any and all those receiving the benefits of this Code, throughout the United States, shall participate in fair proportion of the cost of administration thereof. Article IX — Licensing Section 1 . As the stability of the Industry and the ability to carry into effect the purpose and intent of this Act depend entirely upon the complete cooperation of all those engaged in the manufacturing branch of the Retail Fur- Industry, and with a view to effectuating such complete stabilization, all persons that are members of the appli- cant associations proposing this Code shall by virtue of their member- ship be deemed collectively to have been licensed to do business in this industry under this Act. Sec 2. Any and all persons engaged in the business of manufac- turing, producing, servicing, storing, cleaning, renovating, remodeling, or repairing of furs made from furs or skins, anywhere in the United States, if they are not members of this association submitting this Code, or any other applicant association, or of any other duly con- stituted Association or Associations with, will hereafter become a party hereto, and are authorized by the Administrator to act under this Code, shall promptly, following the effective date of this Code, obtain and procure from the Administrator, subject to the approval of the National Emergency Control Board, a license or permit to engage, conduct or to continue in business, and participate in the cost of administration of this Code, which will conditioned upon the appli- cant of such application to comply with all and every of the provisions of this Code and the amendments thereto, and such other and further regulations as may be prescribed by said National Emergency Control Board together with the Fur Administrator. Article X — Labor Provisions Section 1 . Pursuant to subsection (a) of Section 7 of the National Industrial Recovery Act and so long as the Code shall be in effect, the Code shall be subject to the following conditions: (a) Employees shall have right to organize and bargain collectively through representatives of their own choosing and shall be free from the interference, restraint, or coercion of employers of labor, or their agents, in the designation of such representatives or in self-organiza- tion or in other concerted activities for the purpose of collective bargaining or other mutual aid or protection. 11 (b) That no employee and none seeking employment shall be required as a condition of employment, to join any company union or to refrain from joining, organizing or assisting a labor organiza- tion of his own choosing; and (c) That employers shall comply with the maximum hoars of labor, minimum rates of pay, and other conditions of employment, approved or prescribed by the president. Sec. 2. That there will be no discrimination against employee, because of race, creed or sex, or any impairment of, or any inter- ference of any right of such employee to belong or not to belong to any lawful society, fraternity, union or any other organization. Article XI — Arbitration Provisions Any complaint, difference, controversy or question or fair compe- tition arising under or out of this Code, or relating to standards as to maximum hours of labor, minimum rates of pay or other working conditions provided for therein, or concerning the interpretation or application of any provision thereof, shall be submitted to arbitra- tion in accordance with the ruling of the Administrator, and/or the National Emergency Control Board of the Retail Manufacturing Furriers of America, Inc. Article XII — Monopolies Section 1. This Code is not designed to promote monopolies and shall not be availed of for that purpose. Sec 2. The provision of this Code shall not be interpreted or administered as to eliminate or oppress small enterprises or to dis- criminate against them. Article XIII — Deputization The Administrator is expressly authorized to deputize the com- mittee named herein and /or his or its representative or representa- tives, to do and perform such acts as may be necessary to carry into effect the purpose and intent of this Code. Article XIV — Supplemental Codes Section 1. This Code and all the provisions thereof are expressly made subject to the right of the president, in accordance with the provision of Clause 10 (b) of the National Industrial Recovery Act, from time to time to cancel or modify, any order, approval, license, rule, or regulation, issued under Title I of said act, and spe- cifically to the right of the President to cancel or modify his approval of this Code or any conditions imposed upon his approval thereof. Sec. 2. Such of the provisions of this Code as are not required to be included therein by the National Industrial Recovery Act may, with the approval of the president, be modified or eliminated as changes in circumstances or experience may indicate. It is contemplated that from time to time, supplementary provisions to this Code, or additional Codes, will be added or substituted for approval of the President to prevent unfair competition and price and other unfair and destructive competitive practices and to effectuate the other 12 purposes and policies of Title I of the National Industrial Recovery Act consistent hereof. Article XV — Qualifications The intrusion of numerous outside elements, utterly unskilled and with insufficient experience in the peculiar nature of furs and fur work, necessary for the retention of public confidence in furriers and fur work, is an evil which this Code strives to ameliorate if not to eradicate completely. The ultimate aim of the Retail Manufacturing Furriers of America, Inc., is the licensing, by governmental agency, Trade Administrator or National Emergency Control Board, of all legitimate retail manu- facturing fur establishments. As an initial step toward this end, and for the purposes of this Code, it shall be hereafter deemed an Act or practice of unfair competition for any person or firm to advertise, solicite or execute fur work or fur service of any kind, including storage unless such person or firm is composed of at least one skilled, practical, retail manufacturing furrier actively engaged in the retail fur business or employs skilled fur help, and unless such person or firm maintains, upon his or its own premises, skilled fur help in an adequately equipped fur shop. Any person or persons, firm or corporation engaging in any or all of the services offered by Retail Manufacturing Furriers of America, Inc., shall be governed by this Code of fair competition. Minor rules and regulations pertaining to special closing hours, holidays, special price schedules, etc., may be made and evoked by affiliated associations so long as they do not conflict in any of the provisions of this Act, and are to be sanctioned by the Trade Adminis- trator, or his representative, National Emergency Control Board, or an impartial committee of retail manufacturing furriers of the Retail Manufacturing Furriers of America, Inc. Article XVI — Membership The Retail Manufacturing Furriers of America, Inc., sub- mitting this Code respectfully affirms that it imposes no inequitable restrictions on admission to membership therein and is truly represent- ative of the Retail Fur Manufacturing Industry. CERTIFICATE OF APPROVAL To Honorable Hugh S. Johnson, Administrator National Industrial Recovery Act, Washington, D.C. This is to Certify that the foregoing Code of Fair Competition for the Retail Manufacturing Industry of the United States, as required under the National Industrial Recovery Act, is hereby submitted by the Retail Manufacturing Furriers of America, Inc., of 9 East 48th Street, New York, New York. The above association was organized under the laws of the State of New York in the year 1929. Existing as such, it is composed of about a thousand retail manufacturers throughout the country, taking within its fold the following affili- ates of recognized retail fur manufacturers associations: Greater New York Retail Furriers Ass'n, New York, N.Y. Fur Manufacturing Protective Ass'n of Phila. Inc., Philadelphia, Pa. Furriers Guild of Hartford, Hartford, Conn. State of New Jersey Retail Manufacturing Furrers Ass'n, Newark, N.J. Manufacturing Furriers Ass'n of Pittsburgh, Pittsburgh, Pa. Buffalo Fur Merchants Ass'n, Buffalo, N.Y. Milwaukee Retail Manufacturing Furrers Ass'n, Milwaukee, Wise. Colorado Springs Retail Fur Ass'n, Colorado Springs, Colo. Individual memberships where no groups are formed, are likewise individually enrolled. Our Detroit Association is now in process of once again becoming active, as they have always been a strong unit in our national link of retail furriery. In the States of Texas and Connecticut we are organizing entire State affiliation. Similar requests have come to use from local groups, such as, Balti- more, Md., Akron, Ohio, Duluth, Minn., Salt Lake City, Utah, Norfolk, Va., Middletown, N.Y. We are also allied with the entire Furriers Guild of Canada, where one of our Vice Presidents, namely Mr. Charles De Guerre, was former President of the Toronto Furriers Guild. Some of the nonaffiliate retail fur associations, such as Spokane, Baltimore, Washington, D.C, San Francisco, and others have called upon us for assistance and advice in drafting their local Codes. Most of these associations have endorsed our Code of Fair Practices in its entirety, with the exception of labor, due to the difference of their sectional and geographical standards of living. How- ever, the RETAIL MANUFACTURING FURRIERS OF AMERICA, INC.'s Code in its revised form, has amply made provisions for this important phase. Retail Manufacturing Furriers of America, Inc. By Sidney A. Haas, President. Dated, New York, New York, August 30, 1933. [seal.] (13) o UNIVERSITY OF FLORIDA 3 1262 08851 7734