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In terms of internal resources, our Company leadership is committed to industry best practices in labor and human rights. Our Sustainability department supports that commitment, and has since its inception in 1999. Our Sustainability department operates with a dual charter of protecting

environmental and social imperatives in our supply chain and product lifecycle. This department disseminates and updates our policies, solicits employee engagement with social and environmental initiatives, and generally advances the agenda of Corporate Social Responsibility in the United States and abroad.

Externally, we leverage independent third-party auditing firms to ensure our partner factories adhere to their promises in the Vendor Code of Conduct. These monitoring firms employ and provide experts who are knowledgeable in local law, attuned to factory risks, and speak local language(s) to perform audits. Using auditors with this level of expertise helps us to minimize risk in our factories abroad.

When we engage a new third party monitoring firm, one or more employees from our Sustainability department may accompany auditors from the monitoring firm to ensure they fully understand and follow our Vendor Code of Conduct

.Auditors visit our partner factories annually or biennially and administer a full audit with every visit. Certain high risk factories or new facilities may receive more frequent audits. Each audit consists of a factory walk-through, confidential interviews with workers, and a review of relative documentation (e.g. payroll, time records, employee age verification, etc.). To maintain the integrity of the audit, the Company does not provide the audit date to the factories ahead of time. However, to ensure the necessary personnel is available and the documentation can be gathered in time, we do offer a two-week window during which the audit will occur.

If any labor issues are uncovered during an audit, the factory must take immediate steps to correct the problem. This begins with creating a corrective action plan within 30 days. The vendor then comes under Company conservatorship to ensure there are no recurrences, which requires regular updates on the corrective measures taken, as well as photographic evidence