CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT DISCLOSURE STATEMENT


RTW Retailwinds, Inc., which owns and operates New York and Company, Fashion to Figure, and Uncommon Sense stores and associated websites, and operates Happy X Nature stores and associated websites (the “Company”) is committed to the manufacture of products in a socially responsible manner. We not only set high standards for quality and value, but we also set forth a mandate for labor practices and a workplace code of conduct to which all suppliers must adhere. Our Code of Business Conduct contains a clear and consistent message that all partners in our supply chain be afforded the labor and human rights to which they are entitled.

The Company’s compliance program consists of announced labor, security and trade compliance audits that are conducted by the Company’s compliance leaders as well as through accredited third-party auditing firms. Our audit questionnaire contains pointed questions to help us identify any red flags in “zero tolerance” areas, such as human trafficking, forced labor, bribery and corruption. Our Code of Business Conduct for associates and our supplier agreements also address our principles and values as they relate to labor and human rights. In keeping with the spirit of our compliance program, we require our suppliers to certify that the materials or minerals used to manufacture our products comply with all laws in the countries where they are manufactured or sourced.

We employ robust corrective action plans that not only address non-compliance areas found during an audit, but we also provide the suppliers with the tools necessary to continue best practices after a corrective action plan has been completed. We build strategic partnerships with our suppliers, and maintain accountability standards and procedures. We are committed to ensuring that the members of our supply chain comply with our Code of Business Conduct and address non-compliance accordingly.

Through experience, we believe that best practices are not only achieved through auditing, but also through verification of the product supply chain. The Company’s compliance leaders, with the assistance of a third-party auditor, conducts risk assessments to identify labor and human rights concerns in the countries in which we do business. We continue to evaluate the assessment findings and mitigate identified risks where appropriate.

In addition to providing our external partners with best practices, we also provide best practices to our internal partners. Our associates and leaders with direct responsibility for supply chain management participate in training that provides an in-depth look at labor and human rights violations that include, but are not limited to, human trafficking with the intent of forced labor. The training provides tools to help identify red flags in human trafficking and forced labor, root cause factors, and the framework that can help mitigate identified risks. By keeping our internal supply chain leaders abreast of possible risks, we empower them to make decisions that will better support our objectives and goals for our social compliance initiatives.

We believe our dedication to social compliance represents our commitment and our obligation to our shareholders, associates, suppliers and customers. Our goal - to ensure labor and human rights for all partners in our supply chain - is unwavering, and we will continue to develop processes and implement controls to help us achieve that goal with respect and integrity.