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Just as a consumer has choices, at Luxisocool, we take our business choices seriously, including in the way we obtain the products we sell. We strive to have a positive impact not only within our stores and corporate family, but also upon hundreds of vendor manufacturing facilities throughout the world which make our products, as well as their employees.

We see these choices as part of a work in progress and that there is always more to do.

1. Supplier and Vendor Social Compliance and Ethical Sourcing

We care not only for our employees but also for the employees of hundreds of vendor manufacturing facilities throughout the world which make our products. We want all of these employees also to work in safe and healthy environments and to provide products to you, the consumer, which are made by such employees.

Therefore, our Corporate Social Responsibility program includes the Luxisocool Vendor Audit Program. While many of our vendors have worked with Luxisocool for a number of years and are trusted, all suppliers and vendors must provide factory contact information and all factories must participate in the audit program.

   Here are Some Important Elements of our Program:

   - Luxisocool enters into a comprehensive agreement with each of our vendors and their factories under which they promise to utilize legally qualified workers, pay them wages which are fair and legal in their jurisdiction, and provide an environment that complies with their legal requirements. Our agreement also covers issues of time off, free association rights, nondiscrimination, environmental protection and security, and prohibits the use of forced or slave labor, child labor, or prison labor.

   - These Vendor Compliance Standards were developed to comply with industry standards, local labor laws, the California Transparency in Supply Chain Act, the UN Declaration of Human Rights and the ILO Core Conventions.

   - We have a highly trained Vendor Compliance Team, which promotes and enforces lawful and ethical operations at our third-party factory sites. The Team accomplishes this enforcement by conducting inspections of our active non-US Vendor manufacturing facilities on a random basis to ensure The Vendor Compliance Standards are understood, respected and followed. We also visit most factories before We hire them, to ensure their facility and operations meet with our standards.

   - After each factory visit, the Vendor Compliance Team provides a written evaluation of the factory, including any action items which may need correction prior to the next visit. We also do our best to provide ongoing information, advice, and support on fair labor, health and safety, and related issues.

   - Our goal is to work with our factories to help them improve and ensure consistent compliance. However, in the event that we discover very serious violations or violations which are not corrected within a reasonable time period after our corrective action plan has been issued, we may terminate that factory from our roster.

We believe this process assists in guarding against potential unsafe conditions, workplace injuries or mistreatment, and also results in an overall improvement in factory efficiency and product quality standards.

   Special Note About the 2012 California Transparency in Supply Chain Act

   On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will go into effect, requiring retailers and manufactures above a certain size and doing business in California to disclose measures used to track possible slavery and human trafficking in their supply chains. The disclosure is aimed at providing information to consumers to allow them to make better, more informed choices about the products they buy and the companies they support.

   We make the following disclosure in compliance with the Supply Chain Act:

   1) Do we engage in third-party verification to evaluate and address human trafficking and slavery risks in product supply chains? We regularly evaluate and address human trafficking and slavery risks in product supply chains through inspectors who are employees of the company and who are also tasked with investigating internal or third-party reports of this nature.

   2) Do we conduct audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery? We conduct audits of our suppliers through inspectors who are employees of the company and check for compliance with company standards for trafficking and slavery. We conduct both announced and unannounced audits.

   3) Do we require direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which are doing business? We require such certification from our direct suppliers.

   4) Do we maintain internal accountability standards and procedures for employees or contractors failing to meet company standards on slavery and trafficking? We maintain internal accountability standards and procedures for employees and contractors who fail to meet company standards in this regard.

   5) Do we provide company employees and management, who have direct responsibility for supply chain management, with training on mitigating risks of slavery and trafficking in supply chains? The company provides training on detecting and enforcing procedures against slavery and human trafficking to such employees and management.