CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT

totes»isotoner takes respect for human rights and compliance with laws very seriously. We select business partners that share our commitment to ethical practices and agree to operate under our standards of business conduct, including our Factory Workplace Code of Conduct. Each factory that manufactures product for totes»isotoner must understand and agree to operate its factory in compliance with our Code of Conduct.

• Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party. (Certification)
  
  Under the Code of Conduct, totes»isotoner suppliers certify that they will conduct business in compliance with the law, including among other things, without child labor, forced labor, harassment or discrimination.
  
  
• Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit. (Verification)
  
  Periodic unannounced audits are performed using our Quality Assurance and Social Compliance staff to ensure compliance with the Code of Conduct. Additionally, many of our customers will request a third party complete a Social Compliance Audit to ensure compliance with their requirements. In both cases these audits will examine in detail various aspects of working conditions, safety conditions and maintained documentation to ensure compliance with the letter and spirit of our Code of Conduct and our customer's Social Compliance requirements.
  
  
• Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. (Audits)
  
  totes»isotoner requires that each factory certify that the totes»isotoner Workplace Code of Conduct standards are met and the factory is in compliance with all applicable laws of the country of manufacture.
  
  
• Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. (Internal Accountability Standards)
  
  Any factory not in compliance with the totes»isotoner Code of Conduct will be notified of the elements of noncompliance, and may be afforded a limited period of time in which to bring operations into compliance. Regarding our Customer Social Compliance Audits, the corrective action planning process is based on the individual customer requirements. Any factory not in compliance after such period (if granted) will be removed from our Core Factory list until compliance is completed.
  
  
• Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. (Training)
  
  Our factories certify that all employees have been informed about the Workplace Code of Conduct standards through oral and written means. A copy of the Code of Conduct, written in both the primary language of the factory and English, is posted for employee review.