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I think you gentlemen possibly will have some questions on this exhibit a little later.

Exhibit B, hereto attached, shows a graph of the employment index of the wool textile industry contrasted with the index for all industries. This graph shows the extent to which employment in the wool textile industry has improved and shows that the index is now 11 percent higher than the average for 1929. The industry during the past year distributed in wages a total 40 percent greater than in 1934. The graph likewise illustrates the unfortunate effect of the unjustified and abortive strike in September 1934.

That is the very substantial dip you will notice for that year.

EXHIBIT B

STATISTICS OF WOOL MANUFACTURE DECEMBER 1935

The chart on opposite page presents graphically the pay roll and employment indexes for wool textiles and for all manufactures for the past 3 years by months and for 3 more years by averages for the year.

The following table sets forth the indexes of employment and pay rolls, the average hours worked, average hourly earnings, average weekly earnings (actual, full time, and adjusted) and the purchasing power of the dollar as published by the National Industrial Conference Board.

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Second, as to excessive hours.-The wool textile industry cannot be charged with working its employees excessive hours. The 40-hour week as established by the code and continued by the approved rules of business procedure has been observed by 95 percent of the industry. That is a conservative statement. Hours of work have not been increased except in a very few instances and then largely due to emergency conditions which were of a temporary nature.

I might say at this point that during the operation of the code the administrator in Washington permitted a deviation in extraordinary circumstances from the hours and other provisions. We have contined the same practice by having a business conduct committee to pass upon those same applications.

Attached hereto is also a copy of the rules of business pro adopted by the industry.

EXHIBIT C

NATIONAL ASSOCIATION OF WOOL MANUFACTUR
OF BUSINESS PROCEDURE FOR THE WOOL TEXTILE

To Members of the Wool Textile Industry:

Subject: Rules of business procedure for the wool textile indus The new suggested rules of business procedure for the wool tex. which retain most of the features of the old code of fair competit under the N. I. R. A. are enclosed for your consideration.

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Child labor is banned and the minimum wage is retained. A new provision has been inserted to prevent the employment of women in any department between the hours of midnight and 6 a. m. This replaces the former prohibition of a third shift. It applies not only to worsted spinning and weaving and knitting but to all other departments. This means that the restrictions provided in the new agreement are based on social grounds and do not provide for the artificial limitation of machinery as such. It is expected that the effect will be practically the same as under the former code but it is felt that it is an advance to have the prohibition based on social grounds rather than on an artificial system of machine limitation.

Section 7A of the old N. I. R. A. referring to relations with employees has been omitted. The question of employee relations seems to have been completely covered by the Wagner labor bill which has now passed the Congress and accordingly it would appear that no further amplification of the Wagner bill need be included.

In order not to make the agreement any more inflexible than the N. R. A. code it has been provided that a business conduct committee will be appointed to serve in much the same capacity as the former code authority. To the business conduct committee, therefore, will go all applications for temporary exemptions and all questions concerning the operation of the agreement. Until their successors are clected the old code authority of the industry will serve as the business conduct committee.

Contract forms for each division, which are simplifications of the forms used under the N. R. A. code, are also enclosed. These have already been considered and approved by subcommittees acting for each division. There will be no other rules for the separate divisions; the provisions of these standard forms incorporating all of the old rules which it is proposed to retain. It should be noted that the business conduct committee is to assist in the enforcement of contracts providing only that they follow these standard contract forms.

The rules are to become effective upon ratification by members of the industry owning, controlling, or operating not less than 75 percent of the machinery of the industry. Copies of the proposed rules and of the standard forms of contracts are being sent to all known members of the wool textile industry.

The reporting of prices for goods or services and the filing of copies of contracts have been discontinued upon the advice of counsel. This applies to the filing of minimum tariffs by the commission combers, the filing of copies of contracts for yarn, of price lists for blankets and the filing of copies of contracts or of price lists of piece goods. All the other statistical work of the industry is to be continued. The directors are unanimously of the opinion that the statistical services of the association should be continued and that their value to the industry will increase from year to year as a comparison is developed with preceding periods. The National Association of Wool Manufacturers is designated as the statistical agent to continue either by itself or in conjunction with other agencies the statistical work of the industry.

Will you kindly return the enclosed ballot promptly with any comments you may care to make?

Respectfully submitted.

NATIONAL ASSOCIATION OF WOOL MANUFACTURERS.
ARTHUR BESSE, President.

RULES OF BUSINESS PROCEDURE FOR THE WOOL TEXTILE INDUSTRY, JUNE 27,1935

To maintain improved labor standards, to foster fair competitive opportunities, and to prevent abuses and injurious and unfair trade practices, the following rules of business procedure are herewith adopted:

1. Scope of industry.—Members of the wool textile industry shall include all persons, firms, associations, trusts, and corporations who engage in the operations detailed in appendix A, attached hereto and made a part hereof.

2. Minimum wage.-No worker employed north of the Mason-Dixon line shall be paid at a rate of less than 35 cents per hour or $14 per week of 40 hours, and no worker employed south of the Mason-Dixon line shall be paid at a rate of less than 321⁄2 cents per hour or $13 per week of 40 hours. Learners shall be considered as employees and must be paid at a rate not less than the prescribed minimum.

Workers employed at piece rates shall be paid rates which will produce an aggregate of not less per week of 40 hours than the minimums above provided. If a worker employed at piece rates earns less than the prescribed minimum for

a week of 40 hours his pay shall be made up to that minimum, but credit for piece workers may be averaged over not to exceed two weekly pay periods.

3. Hours of labor.-No worker shall be employed in excess of 40 hours per week except as hereinafter provided or as specially approved by the business conduct committee.

This limitation shall not apply to: Office employees receiving more than $30 per week; repair shop crews, engineers, electricians, firemen, sales, and supervisory staff; shipping, watching, and outside crews. Office employees receiving $30 a week or less may not work over 48 hours in any one week or more than 40 hours averaged over a 13-week period.

4. Employment of minors.-No minor under the age of 16 shall be employed. 5. Hours of employment of women.-No woman shall be employed between midnight and 6 a. m.

6. Statistics. The National Association of Wool Manufacturers is hereby appointed the official statistical agent for the members of the wool textile industry operating under these rules.

Such members shall furnish to the National Association of Wool Manufacturers or such statistical bureaus or agencies as it may see fit to appoint to cooperate with it in compiling data, periodic reports containing such information as may be requested with respect to number of employees, total hours of labor employed, total wages paid, wage rates, machine hours, figures on production, orders, billings, stocks on hand, and such other data as such association may reasonably require for the computation of statistics on the operations of the industry.

7. Contract forms.-Standard contract forms shall be adopted for each division of the wool textile industry or each subdivision where necessary. Each such standard form shall be recognized as setting forth the approved selling practices of the division or subdivision of the industry in question.

8. Administration.-A business conduct committee composed of six members shall be elected annually in the month of February by the members of the wool textile industry subscribing to these rules. The election shall be by ballot taken by mail and shall be conducted by the National Association of Wool Manufacturers. Until their successors are elected, the members of the former code authority of the wool textile industry shall act as the business conduct committee. Requests for exemption and all matters arising in connection with these rules of business procedure shall be referred to the business conduct committee, which shall have power to authorize limited exemptions upon presentation of data justifying such procedure.

The business conduct committee or its agents shall lend assistance in securing the enforcement of contracts, providing such contracts are executed on the standard contract forms duly adopted for the respective divisions or subdivisions.

9. Effective date. These rules shall be recognized as setting forth the standards for business conduct of the members of the wool textile industry upon ratification by members of the industry owning, controlling or operating not less than 75 percent of the machinery of the industry.

10. Modification.-The provisions of these rules may be modified, altered or amended by agreement of members of the wool textile industry owning, controlling or operating not less than 75 percent of the machinery of the industry. Any proposed modification, alteration or amendment shall become effective upon its ratification by members of the industry owning, controlling or operating 75 percent of the machinery of the industry.

APPENDIX "A".

DEFINITION OF WOOL TEXTILE INDUSTRY FOR RULES OF
BUSINESS PROCEDURE

1. Members of the wool textile industry shall include all persons, firms, associations, trusts, and corporations who engage in:

A. The performance of any of the following operations, whether carried on separately or as a part of a series of operations:

(a) The carbonizing, dyeing, and picking of rags and clips containing 10 percent or more by weight of animal fibers other than silk, and the garnetting of fiber from rags, clips, and mill waste containing 10 percent or more of animal fiber other than silk.

(b) The scouring and carbonizing of wool except the scouring and carbonizing of wool by firms who themselves spin the wool into yarns that will subsequently be manufactured into carpets and rugs or underwear.

(c) The combing and recombing of all top on Bradford and French combs except top combed by firms who themselves manufacture the yarn resulting therefrom into carpets and rugs.

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