California Transparency in Supply Chain Act Disclosure

The Global Custom Commerce, its affiliates, divisions, and subsidiaries strive to conduct business in a responsible manner. As we expand our business activities and work with suppliers domestically and globally to meet customers' needs, it is important to preserve our collective commitment to human rights and safety in the workplace.

The Global Custom Commerce expects that all suppliers will abide by all applicable international and local laws, rules and regulations in the manufacture and distribution of merchandise or services provided to The Global Custom Commerce. All suppliers are strongly encouraged to exceed The Global Custom Commerce's guidelines and promote continuous improvement throughout their operations.

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. This law is designed to increase the amount of information made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Since 2005, The Global Custom Commerce has had a set of Social and Environmental Responsibility (SER) Standards which all suppliers are obligated to comply with by contract. Specifically our standards state the following for "Forced Labor":

"Suppliers will not use of any form of involuntary labor including forced, prison, indentured, bonded, slave, or human trafficked labor."

We also actively monitor child labor in our supply chain which can be associated with slavery and human trafficking:

"Suppliers must not employ workers younger than the greater of 15 years of age -- or 14 where the local law allows such an exception consistent with International Labor Organization guidelines -- or the age for completing compulsory education or the minimum age established by law in the country of manufacture. In addition, Suppliers must comply with all local legal requirements for the work of authorized young workers, particularly those pertaining to hours of work, wages, and working conditions."

Global Custom Commerce utilizes internal staff as well as a number of third-party social responsibility firms to monitor and prevent human rights abuse in our supply chain.

Our efforts include:

Supply Chain Verification

In addition to the contractual obligations outlined above, Global Custom Commerce performs factory assessments (Audits) of suppliers of private brand and direct import products on a periodic basis. Every factory receives an Audit at least every two (2) years. The majority of our factories receive a new Audit every six (6) months to one (1) year, while those achieving a 95% score or better receive a new audit less frequently. These assessments are conducted by trained individuals from our internal SER team as well as our third-party social responsibility firm partners. Notably, almost a quarter of the questions used in these Audits focuses on the risks associated with the various types of forced and child labor and other national laws associated with them.

Supplier Audits

Global Custom Commerce evaluates and verifies suppliers' compliance with our SER Standards via on-site auditing. As described above, we audit all factories manufacturing private brand and direct import products while contractually holding our national brand partners to the same level of due diligence. Announced audits are conducted prior to placing any purchase orders with a private brand or direct import supplier. We also utilize pre-source assessments, specific response Audits when we are directly made aware of an issue by any source, and a comprehensive risk based re-audit program, which include both announced and unannounced audits, to ensure these factories are monitored on a continuous basis. At the conclusion of every Audit where an issue of noncompliance is found, a Corrective and Preventive Action (CAPA) plan is created with firm timelines based on the level of risk (High 30 days, Medium 90 days). Global Custom Commerce has a policy of verifying the CAPA implementation to confirm that the factories are meeting the commitments set forth in the CAPA plan. Evidence of forced or child labor during any of the aforementioned discovery methods is deemed a "Critical Deficiency" and results in a multi-step engagement between The Global Custom Commerce and the supplier. This engagement consists of three (3) visits to the factory over a six (6) month period. At the completion of this engagement, a new Audit is required and the factory must demonstrate systemic improvements or risk termination by The Global Custom Commerce.

Supplier Certifications

The Global Custom Commerce has a Supplier Buying Agreement in place with our suppliers requiring them to comply with international standards and applicable laws and regulations, including those related to forced labor and child labor as specified in The Global Custom Commerce's SER Standards. In the event of a non-compliant supplier or factory, we work with our suppliers on remediation efforts. Notwithstanding the above, we have a termination mechanism in place which defines the circumstances under which a factory or supplier will be excluded from conducting future business with The Global Custom Commerce.

Internal Accountability

We believe in Respect for All People and Doing the Right Thing, which are emphasized to all associates as part of our values wheel. To help enforce our values, The Global Custom Commerce has an anonymous hotline available to our associates for the purposes of reporting violations of company policy or legal requirements. This resource is available 24 hours a day, 365 days a year and each report is investigated by our corporate compliance team.

Training

Global Custom Commerce trains internal employees responsible for sourcing products on how to identify and respond to social and environmental responsibility issues, such as forced labor or child labor.