California Transparency in Supply Chains Act

We are providing the following information required by the California Transparency in Supply Chains Act 2010 (SB657).

Talbots is committed to the prevention of forced labor and human trafficking in our global supply chain, and we strive to ensure suppliers making Talbots products provide acceptable working conditions. Talbots Supplier Code of Conduct outlines our expectations for all of our suppliers, including contractors, vendors, and agents. Our Code prohibits any type of forced or involuntary labor, whether prison, indentured, bonded, or other compulsory labor, and requires suppliers to ensure there is no forced labor or human trafficking in their supply chains.

We take the following measures to help ensure that the manufacturing of Talbots products is free from forced labor and human trafficking.

Verification: Talbots social responsibility team must approve all new suppliers before they may manufacture for Talbots. Before a factory may produce garments under the Talbots label, we require that the factory undergo and pass a social responsibility audit. Once approved, contract factories are subject to ongoing factory monitoring. In connection with its initial and ongoing assessments of factories, the Talbots social responsibility team regularly reviews the U.S. Department of State's annual Country Reports on Human Rights Practices and Trafficking in Persons Report; the U.S. Department of Labor's List of Goods Produced by Child Labor or Forced Labor; and research and reporting by international organizations and other sources to assess supply chain risks related to forced labor and human trafficking.

Auditing: Talbots factory monitoring program evaluates factory compliance with Talbots Supplier Code of Conduct and applicable laws and regulations. Approved apparel factories are audited at least annually by Talbots agents and independent third parties, who conduct announced and unannounced audits to assess compliance with Talbots standards. The audit schedule is determined in part by our assessment of the risk of human trafficking or forced labor. Talbots audit procedure collects information about migrant and foreign contract workers, and includes a standalone section on foreign contract workers that digs deeper into the specific risks faced by this population. Facility tours, document review, and worker interviews are a required element of all Talbots audits.

Talbots audits look for root causes of violations and help outline appropriate steps to achieve compliance. Corrective action plans are issued for non-compliances, and suppliers are expected to remedy violations in a timely fashion. Talbots sourcing is regularly advised of factories' compliance performance, and Talbots reserves the right to discontinue business with suppliers who fail to make credible efforts to improve.

Certification: Talbots Supplier Code of Conduct and Supplemental Guidelines provide clear guidance to Talbots expectations with regard to working conditions, including the prohibition of all forms of forced labor and human trafficking. We require all direct suppliers to certify their compliance with Talbots Supplier Code of Conduct at the beginning of the business relationship and regularly thereafter. In addition, Talbots requires suppliers to maintain adequate records to demonstrate compliance, such as proof of age for all workers, timesheets, and payroll records, which are reviewed for compliance as part of Talbots audits.

Internal Accountability: All Talbots employees and contractors are expected to conduct themselves according to the guidelines described in the Talbots Code of Business Conduct and Ethics. This includes wage and hour laws which address actions that would be complicit with forced labor. Talbots agreements with buying agents also require compliance with Talbots Code of Conduct and compliance standards.

Training: Talbots recognizes the importance of educating employees with global sourcing responsibilities about the risks of forced labor and human trafficking. In 2017, all employees and executives on Talbots sourcing team were required to undergo training in the identification and prevention of forced labor.