Our Company is committed to conducting business in a lawful, ethical, and responsible manner. We expect our vendors to respect and adhere to the same business philosophy in the operation of their businesses.

California law requires certain companies doing business in California to disclose their efforts to address the concerns regarding slavery and human trafficking raised by the California Transparency in Supply Chain Act of 2010.

Consistent with our commitment, the Company conducts an ongoing internal assessment of its direct supply chain aimed, among other things, at understanding the potential challenges in a global supply chain of the risks of human trafficking and slavery. In that regard, we review government reports and updates from expert organizations and companies dedicated to social compliance issues.

We also have a Vendor Code of Conduct which is based upon principles of ethical business practice and recognition of the dignity of others. The Vendor Code of Conduct specifically prohibits the use of involuntary or forced labor, human trafficking, child labor, and harassment and abuse and requires compliance with applicable laws and regulations. We require our direct product vendors and manufacturing facilities to agree and abide by our Vendor Code of Conduct and supplemental vendor requirements and to certify that they obtained from their suppliers and subcontractors written assurances to also commit to these principles.

We engage third-party auditing firms to perform announced, semi-announced, and unannounced audits to evaluate compliance with our Vendor Code of Conduct and supplemental vendor requirements. Vendors are required to address any compliance issues identified during an audit or reaudit. Failure to address and correct violations of our Vendor Code of Conduct can result in a reevaluation of our business relationship with such vendor up to and including the termination of such business relationship. However, continuous improvement is a tenet of our compliance program.

We maintain internal accountability standards and procedures for employees regarding our commitment to the principles set forth in the Vendor Code of Conduct. In addition, the Company maintains confidential channels for employees and vendors to anonymously report related concerns.

We provide training to employees and management who have direct responsibility for supply chain management of direct finished goods geared toward raising awareness of the risks associated with human trafficking and slavery in supply chains, identifying potential risks, and addressing those risks if human trafficking and slavery are suspected.