CA Transparency

As a condition of doing business with our company, requires all vendors and agents that we contract with to ensure that all products are made and delivered in full compliance with all applicable laws and regulations. Our vendors and agents are also required to abide by's own specific requirements, even if they go above and beyond what's required by any applicable law.

When we identify areas of non-compliance, our goal is to work with our vendors to help resolve issues, improve compliance and promote better working conditions. That said, we have a zero tolerance policy for extreme violations such as the use of child labor, forced labor, or human trafficking and any such violation would result in termination of our business relationship with the offending vendor.

California Transparency Supply Chains Act. respects internationally recognized human rights standards and believes that no business should ever be complicit in any human rights abuses. Pursuant to the California Transparency in Supply Chains Act, (along with all other retailers and manufacturers with annual sales in excess of $100 million who do business in California) is required as of January 1, 2012 to publicly report on the efforts we are undertaking to ensure that our products are made without the use of slavery or human trafficking.

The California Transparency in Supply Chains Act, S.B. 657, requires retailers and manufacturers that do business in California and have in excess of $100 million in annual sales to state to what extent, if any, they are undertaking efforts to mitigate the risk of human trafficking and slavery in their supply chains. The following provides a summary of's efforts.

All vendors we contract with currently sign an acknowledgment that they are in compliance with all local and international laws, rules and regulations, including but not limited to laws relating to the employment conditions of their respective employees such as: (a) wage and hour, labor and child labor; (b) health and safety; (c) labor and workers' rights and practices; (d) discrimination; and (e) environmental laws and regulations.

Our updated vendor on-boarding procedures require vendors and agents to certify that (1) all goods (including all materials incorporated therein) have been produced and delivered in full compliance with all applicable local and international laws, rules and regulations, including but not limited to those relating to wage and hour, labor and child labor, forced labor, slavery and human trafficking, health and safety, labor and workers' rights and practices, discrimination, environmental, and customs/trade, as well as with all standards and requirements, including as set forth in its Vendor Handbook, purchase order terms and conditions and Code of Vendor Conduct; and (2) all of their own facilities, as well as all of their suppliers and factories, whether owned or contracted, have a compliance program in place and that all goods are produced in full compliance with all such laws and requirements, including all that pertain to the prevention of human trafficking and slavery. partners with a third party, independent consulting and auditing firm to assist us in reviewing, updating and enforcing our standards for compliance and to help us ensure our vendors abide by all laws and requirements, including those that prohibit the use of slavery or human trafficking. We are also evaluating the extent to which our vendors have previously been subject to independent audits and certified by independent auditing firms. Additional independent audits will be undertaken annually with identified vendors based on our evaluation of several criteria, including the annual dollar volume of goods placed with the vendor, the vendor's compliance record to date, and the existence of other third party certifications, among other factors.'s Trade Compliance team has conducted a risk assessment of our supply chain sourcing countries specific to human trafficking and slavery by utilizing advisories published by the US Department of State, the US Department of Labor and the United Nations Office on Drugs and Crime. Our efforts to assess and mitigate these risks are ongoing. As noted above, has an independent consulting and auditing firm to advise us generally on our supply chain policies and practices and to help us with our mitigation and enforcement efforts going forward. As part of this engagement, and in addition to our ongoing internal efforts to educate our employees on ethical supply chain practices, the firm will assist us with the development of a training program for all employees responsible for supply chain management and compliance. has a Code of Business Conduct and Ethics which requires all employees, directors and officers to, among other things, comply at all times with all laws, rules and regulations applicable to the company or its operations. Moreover, all employees have a duty to report any known or suspected violation of the Code, including any violation of the laws, rules regulations or policies that apply to the Company. Failure to abide by our Code can result in disciplinary action up to and including termination. In addition to its existing requirements applicable to its vendors, has developed a new Code of Vendor Conduct ("COVC") that specifically references and prohibits the use of slavery and human trafficking. All vendors will be required to abide by the COVC as condition of doing business with