CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

The Rockport Company, LLC (“Rockport”) values its strong reputation for honesty and integrity throughout the industry. Guided by a commitment to maintain our high standards and ethical conduct in our business practices, the workplace and the environment, we expect our employees, business partners and suppliers to conduct all business activities in a responsible and ethical manner.

We are committed to ensuring that the guidelines embodied in our “ENGAGEMENT CRITERIA FOR SOURCES, VENDORS & OTHER BUSINESS PARTNERS” are followed by our employees, suppliers, and business partners, in all global locations where our portfolio of brands are produced or sold. We expect our suppliers and business partners to comply with these standards while enforcing these same standards throughout their supply chain. We will monitor activities through on-site inspections, signed manufacturing agreements, and third party assessments. We favor partners who contribute to the betterment of the communities in which they operate.

Verification of Supply Chain:

Potential factories are evaluated before becoming an approved Rockport factory to assess risks related to Health & Safety, Environment, Employment Practices, Freedom of Association and Security Standards. We perform this evaluation with third party audits of the facility and work environment. Once approved, factories must commit contractually to meet the standards set by our ENGAGEMENT CRITERIA FOR SOURCES, VENDORS & OTHER BUSINESS PARTNERS or be subject to restriction or termination of their contractual relationship with us. No production of Rockport products may take place in a factory until an audit has been completed and an agreement has been signed.

Supplier Audits:

Rockport reserves the right to verify a supplier’s compliance with the ENGAGEMENT CRITERIA FOR SOURCES, VENDORS & OTHER BUSINESS PARTNERS through third party audits or onsite inspections including interviews with a supplier’s employees in order to evaluate compliance with standards for employment, wages, child labor, human trafficking and slavery, among others. If we become aware of any action or condition that is not compliant with our standards, we demand immediate corrective actions. Rockport reserves the right to terminate any supplier who does not comply with our standards.

Certification of Materials:

Rockport expects all suppliers to certify their compliance with our standards and that they have enforced those standards throughout their supply chain. Suppliers must also certify that the materials incorporated into Rockport products comply with all laws, including those regarding human trafficking, child labor and slavery of the country or countries in which the supplier is doing business.

Internal Accountability of Standards:

Rockport expects its employees, suppliers and business partners to comply with its Code of Conduct and ENGAGEMENT CRITERIA FOR SOURCES, VENDORS & OTHER BUSINESS PARTNERS. We expect our employees to uphold and live our commitment to high standards and ethical conduct in their day-to-day responsibilities.

Employee and Management Training:

All Rockport employees receive annual training on our Code of Conduct which requires compliance with laws and our policies including our ENGAGEMENT CRITERIA FOR SOURCES, VENDORS & OTHER BUSINESS PARTNERS, with a focus on mitigating risks.