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California Transparency in Supply Chains Act Disclosure Statement

Overview

Schurman Retail Group is committed to the highest standards of product quality and business integrity. We want to ensure that working conditions in our supply chain are safe and just, that workers are paid fairly and treated with respect and dignity, and that our suppliers’ manufacturing processes are environmentally and socially responsible. We believe our company culture thrives when our goals are aligned and all our expectations made clear. We partner with experts in the field of responsible sourcing, such as Made In A Free World® and Intertek, to ascertain and evaluate potential supply chain risks and facilitate an open dialogue on the subject with our suppliers. We believe the more that human trafficking is discussed openly, the better situated we will be to adequately address violations within our supply chain.

Verification

All Import Vendors are required to go through a tightly managed screening process prior to engaging in business with Schurman Retail Group. The Schurman Retail Group Product Safety and Compliance Department, with the help of third party sourcing agents, is responsible for screening vendors. The verification process starts when a vendor applies to do business with Schurman Retail Group and continues in response to the identification of risk factors or areas of concern. During the verification process, Schurman Retail Group considers many factors such as the use of labor brokers, the geographic location of the vendor’s facility, the vendor’s manufacturing processes and workforce profile. If we identify issues of concern, such as the use of illegal employment agencies or the submission of an outdated social audit, we may reject the vendor from moving on to the next stage. In other instances, we may have a third-party perform an independent audit and carefully review the results before proceeding any further with the on boarding process.

Audits

We use independent, third party, social compliance auditors on an as-needed basis to evaluate vendor compliance with company standards for trafficking and slavery in supply chains. The selection of factories for audit is based, in part, on our quarterly review of the supply chain map. Our supply chain map involves a strategic risk assessment, based on metrics such as vendor history, purchase volume, country of origin and product category. Audits are typically scheduled 4-6 weeks in advance; however, our Code of Conduct expressly reserves the right for Schurman Retail Group to conduct unannounced audits which are performed if we determine there is a need for such a procedure. Audit standards are based on the widely accepted, industry driven, Workplace Conditions Assessment (WCA). This audit standard covers 5 key categories: Wages and Hours, Labor, Health and Safety, Management Systems, and Environmental Compliance. Audits not only include inspection of facilities, but extend to review of documents, records, policies, and procedures. Both group and individual worker interviews are also conducted.

Certification

Our Code of Conduct requires that our vendors certify that they comply with the laws, rules and regulations in the regions in which they do business, including those laws, rules and regulations relating to slavery and human trafficking. Such certification extends to sourced materials which are incorporated into supplied final products. Schurman Retail Group's vendor Code of Conduct expressly prohibits forced labor practices, such as the holding of passports, work permits, or identity cards or the deduction of wages for disciplinary purposes. The Code of Conduct also mandates that suppliers keep accurate records demonstrating conformity with the requirements set forth above. Acceptance of our Code of Conduct is a condition to a vendor doing business with Schurman Retail Group. A signed acceptance of Schurman Retail Group’s Code of Conduct must be on file prior to a purchase order being placed. Any violation of the Code of Conduct may result in the termination of our business relationship.

Internal Accountability

All Schurman Retail Group employees are required to agree to uphold our Corporate Code of Business Conduct and Ethics (the “Code”) as a condition to their employment. Our Code covers established standards of conduct and summarizes many important policies, including the company’s stance against human trafficking and slavery. To determine and ensure that Schurman Retail Group employees are complying with company standards regarding slavery and human trafficking, we require each employee to report any known violation through the Company’s normal reporting procedures. Such reports can be made confidentially. All reports will be promptly investigated and anyone found in violation of any part of the Code is subject to corrective action or, termination, depending on the number of non-compliances found and their severity. Schurman Retail Group Human Resources, with the assistance of the Product Safety and Compliance Department, works with employees to develop action plans to resolve any such instances of non-compliance.

Training

Schurman Retail Group employees and management who have direct responsibility for supply chain management must participate in training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. Schurman Retail Group takes a multi-pronged approach to training vendors. Designed to offer flexibility, we use several training modules, dependent on need, to build a socially responsible supply chain. Moreover, an e-learning training component is a required element of all supplier Corrective Action Plans. Occasionally, we may also partner with Intertek to host regional trainings and supplier summits. We believe corporate involvement is integral to sustaining our corporate social responsibility goals.

Review Schurman Retail Group’s Supplier Code of Conduct

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