California Transparency in Supply Chain Law

Many companies manufacturing or selling products in the State of California are required to disclose their efforts (if any) to address the issue of forced labor and human trafficking, per the California Transparency in Supply Chains Act of 2010 (SB 657). This law was designed to increase the amount of information made available by companies with regard to efforts to eradicate forced labor and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support. Forced labor and human trafficking can take many forms, including child labor. Frontgate has a zero-tolerance policy for both forced labor and child labor used in the manufacture of all products that we sell.

I. Policy

We are committed to ensuring that the products we sell are manufactured without the use of child, involuntary, or slave labor.

II. Supplier Code of Conduct

All vendors that provide products to Frontgate are required to certify to Frontgate's Supplier Code of Conduct (the Code), which forms a part of the legal terms and conditions for each order that Frontgate places, and which provides, among other things, that Frontgate's suppliers may not use any form of child, involuntary, or slave labor in the manufacture of the products that we sell. Frontgate extends this restriction to the manufacturers of finished goods that are produced for Frontgate's suppliers.

III. Risk Evaluation

We source our products from many individual suppliers. Because of the range of our retail business, we take a variable, risk-based approach to auditing companies within our supplier base. Our enforcement process, which is described below in more detail, takes into account a number of factors relevant to determining relevant risks related to forced labor and child labor.

IV. Audit and Enforcement

We have a supplier compliance program which requires certain of Frontgate's suppliers to obtain factory inspections at periodic intervals (ranging from every year to every two years) by an independent third-party certification company. Such inspections, which are scheduled in advance with the supplier by the inspection company, will include a review relating to child, involuntary, and forced labor, as well as the other aspects of the Code. The review includes an on-site visit to view factory conditions and review records. In the event that any supplier is found to have used child, involuntary, or slave labor in the manufacture of products supplied to us, we are prepared to immediately cancel all outstanding orders with such supplier. In addition, we have employees in the U.S. and China (the source of most of our imported products) to assist us in our audit efforts.

V. Employee Training And Accountability

All of our global sourcing staff who have direct responsibility for supply chain management, as well as certain other groups of employees who are indirectly involved in sourcing, are required to complete a training program with regard to the Code and our enforcement of it. Any employee who fails to abide by Frontgate's procedures regarding forced labor will be subject to disciplinary action, including potential termination.