California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act requires companies doing business in California to communicate their efforts in addressing the issues of human trafficking and slavery within their supply chains. The Act provides transparency to consumers and allows them to make better, more informed choices about the products they buy and the companies they support. All our suppliers are required by our parent company, Bluestem Brands to comply with Bluestem Brands' Supplier Code of Conduct which is part of Bluestem Brands' Supplier Requirements.

Bluestem Brands strives to achieve and keep a reputation for excellence and ethical conduct in all aspects of our business. We expect the same of our suppliers. Our Supplier Code of Conduct prohibits the support, promotion or use of forced labor, slavery, or human trafficking.

Certification

Bluestem Brands requires suppliers to comply with our Supplier Code of Conduct which outlines our expectations pertaining to social compliance, including no forced or compulsory labor. Our expectations are communicated to prospective suppliers during the process of becoming a Bluestem Brands' supplier. Suppliers agree to read, understand, and comply with the Supplier Code of Conduct which states as follows:

Forced Labor, Slavery or Human Trafficking - Suppliers must not support, promote or engage in forced labor, slavery, or human trafficking in connection with the manufacture of products for Bluestem. All work must be voluntary and workers should be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment.

Supplier Audits

Bluestem Brands reserves the right to audit suppliers and/or any manufacturers, contractors or subcontractors used in the manufacturing or finishing of any products that are ordered by Bluestem Brands or any of its affiliated companies in order to monitor compliance with our Supplier Code of Conduct. Bluestem Brands reserves the right to cease doing business with a supplier who does not comply with the Supplier Code of Conduct. Bluestem Brands reserves the right to cancel a purchase order; return or revoke acceptance of affected goods; require that corrective action be taken or cease doing business with a supplier who does not comply with the Code of Conduct.

Verification

Bluestem Brands' Supplier Code of Conduct requires suppliers of national, market, and private label products to refrain from the direct or indirect use of forced labor or any forms of human trafficking and to verify/certify that their supply chains address these issues. Monitoring our supply chain operations remains a dynamic and evolving process, and we work continuously to improve our procedures and practices to adapt to the changing global environment.

Internal Accountability

Bluestem Brands maintain standards and procedures for employees in its Code of Business Ethics, which requires all employees to act honestly and ethically in all aspects of their work, including their dealings with customers, suppliers, vendors and other employees. All employees receive training on the Code of Business Ethics. Failure by an employee to follow the standards set forth in the Code of Business Ethics may subject such employee to disciplinary action up to and including termination of employment. Both suppliers and Bluestem Brands' employees are encouraged to contact Bluestem Brands with any questions or concerns about our requirements and are expected to report potential ethical or legal violations involving Bluestem Brands' business. All allegations of violations of the Code of Business Ethics or Supplier Code of Conduct are investigated and appropriate responsive action taken.

Training

Bluestem Brands is dedicated to building a socially responsible supply chain. We have plans to develop training to raise awareness and educate Bluestem Brands' suppliers and employees who have direct responsibility for supply chain management about the Supplier Code of Conduct.