California Transparency in Supply Chains Act

Patricia Nash Designs, Inc. (“Company”) are committed to conducting business in a lawful, ethical and responsible manner. Moreover, the Company expects its manufacturing and market vendors (“Suppliers”) to share this same commitment. Accordingly, the Company has implemented certain controls and programs to verify that its Suppliers are meeting the Company’s expectations.

Certification
The Company’s Suppliers certify that they will conduct business in compliance with the law, including, among other things, without child labor, without forced or compulsory labor, without corporal punishment, without discrimination and in compliance with wage and hour requirements, health and safety and environmental laws.

Verification
The Company maintains long-standing business relationships with a limited number of Suppliers which have been vetted through an internal screening process. One element of the screening process includes an internal assessment of the risk that the Supplier will not conduct business in a lawful, ethical and responsible manner, including the prohibition against human trafficking and slavery. The Company’s production, sourcing and compliance personnel visit manufacturing facilities to evaluate and address the risks of a Supplier’s noncompliance with this policy.

Audits
The Company conducts risk assessments and audits manufacturing vendors which meet certain risk-related criteria. Audits and inspections of these vendors may be announced or unannounced and these vendors are required to cooperate in any remedial efforts to ensure future conformance.

Internal Accountability Standards
The Company works with the Suppliers to identify the cause of the non-compliance and to develop an action plan to assure future compliance. that this strategy is in the best interest of the Supplier, its employees and the Company’s customers. Remedial efforts may also include additional audits or inspections. In the event of continued non-conformance or serious violations of this policy, the Company reserves the right to terminate the business relationship with the Supplier.

Training
The Company’s production and sourcing personnel receive on-the-job training, are members of professional affiliations, and attend external training seminars to help further develop their ability to identify and evaluate risks in the supply chain.