California law requires companies to disclose their efforts to address the issues of slavery and human trafficking in their supply chains.  Accessory Exchange LLC (the “Company”) has a Code of Conduct which is based on principles of ethical business practice and recognition of the dignity of others.  The Code of Conduct is applicable to all of the Company’s suppliers.  The Code of Conduct expressly prohibits the use of prison or forced labor, or the acquisition of materials used in the manufacture of our products from a third-party who utilizes prison or forced labor.

The Company participates in supplier audits that are conducted by third-party auditors, our staff and our buying agents to assess compliance with its Code of Conduct.  The vendors selected for audits each year are based on a risk assessment conducted by an analysis of: (i) preliminary inspection of each new vendor’s facility, (ii) detailed questionnaires required from all potential vendors, and (iii) consideration of the anticipated output from each vendor, with follow up procedures planned based on audit results obtained.

All of the Company’s vendors are required as part of their vendor agreement to certify compliance with the Code of Conduct.
Failure of employees to abide by the Company’s Code of Conduct can result in corrective action up to and including termination of employment.  Failure of vendors to abide by the Company’s Code of Conduct can result in corrective action up to and including the termination of all existing and future business.

The Company requires all employees and management who have direct responsibility for supply chain management to take a course directed at raising awareness regarding the risks of human trafficking and slavery in supply chains, identifying potential risks and addressing those risks when human trafficking and slavery are suspected.