California Transparency In Supply Chain Act

Pendleton Woolen Mills, Inc. Disclosures under the California Transparency in Supply Chains Act of 2010

As a retail seller doing business in the state of California, we are required to provide you with details of our efforts to address the issue of slave labor and human trafficking in our supply chain.

Pendleton Woolen Mills, Inc. endorses the Worldwide Responsible Accredited Production (WRAP) principles, http://www.wrapcompliance.org/12-principles, and requires its suppliers to be fully compliant with these principles. We ask that suppliers provide written agreement to fully comply or become certified by the WRAP certification program or other social compliance certification programs whose standards are equal to or greater than WRAP.

The WRAP principles require compliance with laws and workplace regulations, payment of at least minimum total compensation and benefits required by local law, that hours worked daily and weekly do not exceed legal limitations, a safe and healthy work environment, freedom of association and collective bargaining, compliance with applicable environmental rules, observance of environmentally conscious practices, compliance with local customs laws, and maintenance of security procedures. The WRAP principles prohibit involuntary, forced or trafficked labor, child labor, supervisory harassment or abuse, and discrimination

As described above, Pendleton requires all of its suppliers to prohibit the hiring of slave labor and prevent practices that could contribute to human trafficking.

1. Supplier Requirements:

Pendleton requires its suppliers to be fully compliant with the WRAP principles or become certified by the WRAP certification program or other social compliance certification programs whose standards are equal to or greater than WRAP.

2. Supplier Audit Process:

Certified factories that produce our merchandise are audited on an annual or bi-annual basis (based on certification status). The audits are conducted by approved third-party audit firms that are trained to understand the WRAP principles, our expectations, and the specific local language and laws in each country. The audits are conducted on site, and involve discussions with workers, management interviews, a review of pertinent factory records, and a physical inspection of the factory and dormitory. After the audit, any violations of social compliance standards are documented, and a detailed corrective action plan is required. Regular follow-up visits are also conducted to ensure efforts are made to correct any violations.

3. Certification Process:

Pendleton requires social compliance certification by our suppliers that materials incorporated into our products comply with the WRAP principles and all applicable laws and regulations prohibiting slave labor and human trafficking in countries where our suppliers are doing business.

4. Accountability Standards:

We maintain internal accountability standards and procedures for suppliers failing to meet the WRAP principles prohibiting slave labor and human trafficking. If a factory is found to have slave labor or human trafficking through a social compliance audit, the relationship with the factory is subject to termination.

5. Training:

At this time, Pendleton does not provide employees or suppliers with training on human trafficking and slavery.