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California Supply Chain Act

Transparency in Supply Chains Act Disclosure

This disclosure is provided pursuant to the California Transparency in Supply Chains Act of 2010, Section 1714.43 of the California Civil Code, which requires retailers and manufacturers above a certain size and doing business in California to disclose what efforts, if any, they have taken to monitor human trafficking and the use of slave labor in their supply chains.

Our organization recognizes the critical role we play in providing services and selling products that improve the lives of our customers. Doing so requires us to balance the social, environmental and economic benefits and risks of the products we offer, including how they are sourced, manufactured and used.

Suppliers, franchisees and employees play a key role in our efforts to ensure that we manage our global supply chain in a sustainable way. We source products from reputable companies with responsible business practices. Our suppliers are required to agree with our Partner Program Code of Conduct that obligates them to conduct their business in compliance with various laws and ethical business practices including, but not limited to, laws that prohibit slavery and human trafficking. If a supplier fails to do so, we may terminate our business relationship and pursue other legal remedies against the supplier.

Additionally, the Company maintains internal accountability standards and procedures regarding employee compliance with applicable laws, which includes any laws regarding slavery and human trafficking.

The Company produces a confidential, annual compliance report and submits the report to its CEO and Board members so that they may take corrective action and improve the Company’s internal controls and policies as they deem necessary.