CA Transparency in Supply Chains Act

Company Policy Statement on Slave Labor and Human Trafficking

In compliance with the California Transparency in Supply Chains Act of 2010, the underlying retail company hereby discloses to the public its efforts to eradicate slavery and human trafficking from their supply chains. The company itself does not employ slaves or trafficked persons, and has directed and required its direct suppliers/vendors also not to employ slaves or trafficked persons and to perform due diligence with regard to their own suppliers, and ensure that the suppliers further down the supply chain are complying with local laws on slavery and human trafficking. To ensure that the company, its direct suppliers/vendors, or others in the product supply chain, do not employ slaves or trafficked persons, the company requires in its purchase orders as a condition of sale, that its direct suppliers/vendors certify that materials incorporated into the product or merchandise comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business, and that none of the merchandise or products purchased have been manufactured, finished, obtained, packed, transported, or otherwise handled using slave labor or trafficked persons. To that end the direct suppliers/vendors have been further directed in the Conditions of Sale of the company’s purchase orders, to agree to perform due diligence with regard to their own suppliers, and ensure that the suppliers further down the supply chain are complying with local laws on slavery and human trafficking. These Conditions of Sale are also posted on the company’s websites for each of its suppliers/vendors to see. Further, those direct suppliers/vendors who sign Indemnification and Conformity Agreements beginning from and after January 1, 2012, are and shall be required to certify and agree to all of the foregoing.

Since the company is a retailer and purchases its goods as finished products directly from a direct supplier/vendor, but is not involved in the manufacture of such goods and is not familiar with the companies, suppliers, or individuals, manufacturing or supplying the products, materials, or merchandise in the product supply chain, it is not equipped and does not perform verification of product supply chains to evaluate and address risks of human trafficking and slavery, and leaves that to its direct suppliers/vendors (who are more familiar with the companies, suppliers, or individuals involved in the product supply chain, and more knowledgeable, equipped, and responsible for dealing with supply chain management), and relies upon those direct suppliers’/vendors’ warranties, representations, and certifications of compliance contained in the Conditions of Sale in the company’s purchase orders, the Conditions of Sale on its websites, and in the Indemnification and Conformity Agreements of those direct suppliers/vendors who sign the same beginning from and after January 1, 2012. Similarly, the company does not conduct audits of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains, does not maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking (other than requiring such direct suppliers/vendors to indemnify the company), and does not provide company employees and management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products, since the direct suppliers/vendors, who are involved in the supply and manufacture of the merchandise, not the retailer, are more knowledgeable, equipped, and responsible for dealing with supply chain management, and the company relies upon their certifications, representations, and warranties of compliance, and due diligence with regard to their own suppliers as set forth in the Conditions of Sale in the purchase orders and on the websites, and as set forth in the Indemnification and Conformity Agreements of those direct suppliers/vendors who sign the same beginning from and after January 1, 2012, as a means of ensuring that slave labor and human trafficking laws are complied with.