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California Transparency in Supply Chains Act of 2010 Statement

This policy was last updated and posted December 2012.

It is our policy to do business only with those vendors who share our commitment to compliance with fair labor practices. This commitment by vendors must include compliance with fair labor practices in their own operations, and further, must extend to monitoring their contractors and subcontractors to ensure adherence with fair labor practices.

Our Code of Conduct includes provisions regarding the use of prison or forced labor, the use of child labor, local minimum wages or standards, overtime, freedom of movement, personal freedom, and other working conditions. Vendors are required to sign an acknowledgement of the Code of Conduct annually. We will not do business with vendors that do not sign our Code of Conduct. Vendors certify that they and their contractors, subcontractors and suppliers abide by the Code of Conduct. To review our current Code of Conduct, click here.

We maintain internal accountability standards and procedures through our Compliance Program. This includes factory inspections by our associates and third-party inspection services with the goal of verifying our product supply chain to evaluate various risks, including that of human trafficking and slavery. Factories are advised of a time period within which an inspection will be conducted, but are not advised in advance as to the date of the inspection.

If a factory passes inspection, it is periodically re-evaluated. If an inspection discloses that a vendor is not in compliance with the Code of Conduct, we may work with the vendor to establish a corrective action plan, depending on the nature of the non-compliance, or may not do business with the vendor. Certain types of human rights violations will automatically disqualify a vendor from doing business with us. If we choose to allow a vendor to develop a corrective action plan, another inspection will be conducted approximately six months later. If the vendor passes the second inspection, the vendor will be placed into the regular re-evaluation program. Should the vendor fail to pass the second inspection, we will not do business with the vendor.

Our contracts with our vendors require them to comply with all laws and regulations and the Code of Conduct, and require that the vendor assure that its subcontractors, suppliers and factories also comply.

We consider education to be an important part of our supply chain management. Numerous training programs are available to our employees and management, including courses through WRAP (Worldwide Responsible Accredited Production) and webinars through various organizations regarding human trafficking and slavery.

We are and remain committed to compliance with fair labor practices, and will work towards achieving this goal.