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CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

The California Transparency in Supply Chains Act of 2010 was enacted to increase the amount of information made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

We are dedicated to conducting business in a lawful and ethical manner, and it is our expectation that our suppliers also conduct themselves in such a manner.

To ensure that our suppliers comply with these expectations, we have implemented a process that includes:

Compliance with Our Code of Conduct

We obligate our suppliers by contract to comply with our Manufacturing Code of Conduct, which requires among other things, that our suppliers “will not use any forced or involuntary labor, whether prison, bonded, indentured or otherwise.” Our suppliers are expected to require the same standards of their suppliers in turn.

Supplier Audits

We conduct on-site audits of our suppliers in the developing world to evaluate supplier’s compliance with our Manufacturing Code of Conduct and the prohibitions on using child or forced labor. While we may retain third parties to perform these audits and these audits may be unannounced, our employees generally conduct these audits and provide the supplier with notice of the upcoming audit.

Employee Training

We train employees responsible for supply chain management, including those employees who perform on-site audits, on how to identify and respond to supply chain issues, such as forced labor or child labor.

Consequences for Non-Compliance

Suppliers will be terminated if we discover any presence of child or forced labor, and any employees who ignore any signs of child or forced labor are subject to disciplinary action up to and including termination of employment.