The California Transparency in Supply Chains Act of 2010, California Civil Code § 1714.43 (the “Act”), requires retail and manufacturing companies doing business in California to disclose the efforts they have taken to ensure their supply chain is free from slavery and human trafficking. The Company makes the following disclosure in accordance with the Act:
The Company is committed to conducting its business in a lawful and ethical manner and expects its suppliers and vendors to conduct themselves in the same manner. All Company’s suppliers and vendors must adhere to the Company’s Supplier Code of Conduct, which requires compliance with all laws, including laws addressing slavery and human trafficking.
At this time, the Company has not taken specific actions related to (i) verification of product supply chains to evaluate risks of human trafficking and slavery; (ii) conducting audits of suppliers to evaluate compliance with Company standards on human trafficking and slavery; (iii) requiring direct suppliers to certify that their products comply with laws against human trafficking and slavery; (iv) maintaining internal procedures for employees and contractors who fail to meet Company standards; and (v) providing training on mitigating the risks of human trafficking within the supply chain.