CALIFORNIA SUPPLY CHAINS ACT

Johnny Was, LLC is committed to conducting business in a lawful, responsible, and ethical manner. Our Code of Vendor Conduct (COVC) requires that our suppliers ensure a safe, fair, and healthy working environment for the individuals who create our product. Additionally, the COVC sets forth protocols in which suppliers must prevent abusive, exploitive, and illegal conditions in the workplace. All individuals must be treated with dignity and respect. We will only conduct business with suppliers that share our commitment to fair and safe labor practices that are free from any form of human trafficking. The integrity of the production process is equally important as the quality of the products we sell.

VERIFICATION

Our ongoing internal risk assessment program represents a collaborative effort between internal and external business partners. Annually, we evaluate all of our direct manufacturing suppliers to verify that they are not at risk for violating anti-slavery and human trafficking laws. In addition, we evaluate supplier to assure humane working conditions. Johnny Was, LLC uses an internally developed assessment tool to verify compliance to our strict standards stated in our COVC.

SUPPLIER AUDITS

Johnny Was, LLC has a Sustainability Team that conducts annual unannounced compliance audits of our suppliers to identify possible areas of non-compliance with our Code of Vendor Conduct (COVC) or potential risks in our supply chain. Johnny Was will not tolerate, and will investigate, any reports alleging human trafficking and slavery in the supply chain. Any supplier found to be non-compliant to the guidelines set forth in the COVC will result in possible termination of the business relationship.

CERTIFICATION

To ensure that Johnny Was, LLC suppliers respect and enforce our standards, our COVC agreement stipulates that suppliers must abide by our standards, or the contractual relationship is subject to termination. We ask our suppliers to agree and provide workers with a safe and healthy work environment; allow workers freedom of association and collective bargaining; conduct business in compliance with applicable environmental and employment laws; refrain from corrupt practices; and protect against human trafficking and slavery. In addition, we require our suppliers to certify that materials incorporated in our products comply with applicable laws, including those laws that relate to slavery and human trafficking in the country or countries in which they do business.

INTERNAL ACCOUNTABILITY

Non-compliance with our COVC can result in a corrective action plan which employees and suppliers are expected to follow a series of steps to correct the non-compliance in order for them to remain an active supplier. Failure to comply will result in termination of partnership. Throughout the Johnny Was assessment process, the factory management is educated and assisted on any non-compliance issue encountered during our audit.

TRAINING

As part of our efforts to ensure compliance to our COVC and prevent abusive, exploitive, or illegal conditions in the workplace, our Sustainability Team conducts ongoing internal employee and management training regarding our COVC and human rights concerns, including human trafficking and slavery associated with our supply chains. This training specifically covers mitigating risks of human trafficking and slavery within our company’s supply chains of products and is mandatory for those company employees and management that has direct responsibility for supply chain management.

Our Sustainability Team also works directly with facility management and workers in the facilities we monitor. All employees within Global Sourcing and Supply Chain receive training to ensure they fully understand our COVC. In addition to ongoing training, our Sustainability Team continues to strive and become more effective at identifying and correcting issues in our supply chain, which can be hard to detect even for a well-trained and experienced eye.

*ASSESSMENT OF EFFECTIVENESS

Johnny Was, LLC uses a number system to rate facilities’ performance based on various assessments. High-performing facilities with no critical or minor violations receive a rating of 4. Average performing facilities are rated 3, while facilities that need improvement on one or more serious issues are assigned a 2 rating. Facilities with a 1 rating may make it appropriate to temporarily or permanently terminate their ability to product our product if they do not comply within the given timeframe.