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To address the regulations of the California Transparency in Supply Chains Act of 2010 (SB 657):
1. Williamson-Dickie Mfg. Co. assesses the risk of human trafficking and slavery related to the apparel and footwear supply chain. Country Risk Analysis is annually utilized to assess potential trafficking and forced labor risks. Risk assessment is performed either internally or externally, or both. We require that all manufacturing facilities comply with country and local labor laws as well as Williamson-Dickie's Company policies. We hold all of our suppliers to the same standard and require that each abide by our "Code of Business Conduct and Ethics" policy. The Company will not knowingly conduct business with companies that use forced labor or other compulsory labor in the manufacture and distribution of products. The potential risk of labor brokers is considered.
2. Williamson-Dickie Mfg. Co. conducts code of conduct and supply chain security audits of direct suppliers before we enter into any type of agreement or partnership. We have developed and issued a code of conduct to our direct suppliers. Direct suppliers are evaluated on their compliance of our code through audits renewed annually. If during the audit issues are identified, corrective actions are addressed and additional audits may be conducted as necessary to assure compliance. Our audits are generally announced with reserved right of unannounced visits and are performed by either third party or internal auditors, or both.
3. Williamson-Dickie Mfg. Co.'s purchasing agreements require all suppliers to comply with applicable laws within the country of business, international standards, and trade regulations regarding human trafficking and slavery. The Company will not knowingly conduct business with suppliers that use forced labor or other compulsory labor. Verification of purchasing agreements are subject to inspection without notice.
4. Williamson-Dickie Mfg. Co. maintains and rigorously enforces internal accountability procedures for employees and contractors regarding company standards in human trafficking and slavery. In the case of non-compliance, Williamson-Dickie Mfg. Co. reserves the right to examine the specific situation and in conjunction with the supplier develop a best possible strategy for resolution. If cases of non-compliance are not resolved within a timely manner, Williamson-Dickie Mfg. Co. may terminate the business relationship.
5. Williamson-Dickie Mfg. Co. conducts internal training on Williamson-Dickie Mfg. Co.'s code of conduct and supply chain security to ensure the necessary participants in supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including human trafficking and slavery, with a particular focus on mitigating risks. Williamson-Dickie Mfg. Co. requires employees involved in Williamson-Dickie Mfg. Co.'s supply chain to regularly participate in external training programs and seminars on social compliance issues, including a required course on the issues of human trafficking and slavery conducted by the University of Delaware.