Supply Chain Transparency

Supply Chain Transparency: Disclosure - California Transparency in Supply Chains Act of 2010

We actively pursue growth through leadership in environmental, socially responsible and ethical business practices. Corporate social responsibility is core to our operating philosophy, and that commitment drives our dedication to People, Products, Community and the Planet. That commitment extends to our supply chain, and our suppliers play a critical role in ensuring that we manage our business in a responsible manner.

In 2010, the California Transparency in Supply Chains Act (also referred to as SB 657) was signed into law, and statutes enacted under the Act went into effect on January 1, 2012. The Act requires disclosure of particular efforts to eradicate slavery and human trafficking.

We are committed to conducting its business in a lawful and ethical manner and expect our suppliers to conduct themselves in the same manner. We have implemented various policies and procedures in our efforts to prevent slavery and human trafficking in our supply chains. This disclosure will describe some of those efforts. With the assistance of a third-party consultant, we survey our merchandise supply chains in order to evaluate and to address risks of slavery and human trafficking inherent in those activities. This survey forms the basis for additional anti-slavery, anti-human trafficking efforts, including targeted supplier requirements and third-party audits.

We have long used contractual provisions prohibiting the use of involuntary labor and child labor, and requiring compliance with applicable labor and employment laws, in the production of merchandise that we sell. We have a stringent Supplier Code of Conduct ("Code") that sets out specific standards and requirements for any supplier we do business with which includes provisions to protect workers. Among other things, the Code requires our suppliers to allow factory inspections for contractual compliance, as well as for compliance with laws and regulations dealing with child or forced labor and unsafe working conditions.

In our efforts to confirm compliance with such contractual provisions and to document compliance with the California Transparency in Supply Chains Act, each of our merchandise suppliers has been asked to certify that the materials incorporated into the merchandise they supply complies with applicable laws regarding slavery and human trafficking. Suppliers are also required to ensure that any subcontractor used in the manufacturing or distribution of any merchandise to us complies with the same standards.

Any supplier that is not able to provide the foregoing certification will be required, as a condition to continuing to supply merchandise to us, to submit an action plan to achieve such certification within a reasonable period of time. Those suppliers that fail to comply will be subject to increasing levels of discipline, up to and including termination of their relationships.

In an effort to verify supplier responses and to help us identify areas of increased risk of slavery and human trafficking, we are requiring that our suppliers complete a survey identifying measures they have taken, or intend to take, to prevent these abuses.

We have reviewed the risks of slavery and human trafficking presented by various parts of our supply chain and has inspected the factory premises of the suppliers of our own-branded merchandise for evidence of non-compliance with slavery and human trafficking laws. In addition, we have, on a risk-based basis, engaged third-party auditors to review compliance of certain suppliers with international social accountability standards.

Responsible employees have been advised of our prohibitions against the use of slavery and human trafficking in our supply chains. Additionally, we have implemented training requirements for employees with sourcing responsibilities.