California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010 (SB 657) requires retailers and manufacturers above a certain size that are doing business in California to disclose their efforts to eradicate slavery and human trafficking from their supply chains. Prohibition of all forms of forced labor, including slavery and human trafficking, is a core principle of the Company. The Company identifies and uses only those suppliers that demonstrate the willingness and ability to conduct their business in conformity with all applicable legal requirements and ethical standards. The Company is committed to working together with our suppliers to address working conditions and worker exploitation, including forced labor and human trafficking.

Verification

As a condition of doing business with the Company, every supplier must adhere to the Company’s Supplier’s Code of Business Conduct. The Company requires our suppliers to comply with all applicable laws and regulations including laws prohibiting the use of forced labor, child labor, prison labor and human trafficking. All suppliers are required to identify all factories and contractors, domestic or foreign, which they plan to use to produce merchandise and certify that each factory operates in compliance with all applicable labor laws. The Company does not allow the importation of any merchandise manufactured with convict, forced, indentured labor, illegal child labor or through human trafficking.

Auditing

The Company undertakes a multi-layered process to audit its suppliers and confirm compliance with the Company’s Supplier’s Code of Business Conduct. In addition to agreeing to adhere to the Company’s Code of Business Conduct, suppliers must conduct a self-survey of key legal compliance and workplace safety including compliance with the Company’s prohibition on forced labor and human trafficking. Suppliers must further designate an officer to conduct inspections of each facility utilized by that supplier to ensure compliance with the Company’s standards and policies. Additionally, suppliers must submit to on-site inspections conducted by the Company or by specially-trained third parties to confirm compliance. Any supplier which fails or refuses to comply with these standards is subject to immediate cancellation by the Company of all its outstanding orders as well as the refusal to continue to do business with that supplier.

Certification

By signing the Company’s Supplier’s Code of Business Conduct, all suppliers certify their compliance with the Company’s policies including its prohibition on human trafficking and the use of convict, forced, indentured labor, or illegal child labor.

Internal Accountability and Training

The Company requires all employees to act ethically and provides internal training regarding compliance with the Supplier’s Code of Business Conduct. The Company maintains accountability standards and procedures for employees or suppliers failing to meet Company standards including those prohibiting human trafficking and the use of convict, forced, indentured labor, illegal child labor. As with all violations of policy, the Company investigates issues and takes appropriate action up to and including termination.