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CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT

Mount Vernon Mills, Inc. is meeting the requirements of the California Transparency in Supply Chain Act of 2010. The information below sets forth the actions we are taking to ensure our suppliers do not use slave labor or otherwise engage in human trafficking. For the vast majority of our suppliers, this is not an issue because their operations (and those of their suppliers, if any) are located in the United States. They are already subject to the strict standards under U.S. laws that prevent the use of slave labor. We believe our efforts should be focused on our suppliers outside the U.S. For our suppliers located in foreign countries, we use the procedures outlined below. In most cases, our customers are also checking on our foreign suppliers, covering health, safety, environmental and other social issues in addition to slave labor and human trafficking.

Verification. Mount Vernon engages in verification activities to identify, assess and manage the risks of human trafficking at its foreign suppliers. Our verification program centers around audits conducted by both Mount Vernon personnel as well as independent third party auditors. In almost all cases, our customers are conducting their own verifications of our foreign suppliers as well. Suppliers with failing results must address the shortcomings in a timely manner, or they will no longer be used by Mount Vernon as a supplier.

Audit. As indicated above, Mount Vernon personnel and independent third party auditors frequently conduct audits at our foreign suppliers. These audits may be announced or unannounced. The audits cover a variety of compliance issues including Mount Vernon’s prohibition against the use of slave labor and human trafficking. Suppliers are required to correct any deficiencies, or else they will no longer be used as our supplier. In addition, our customers are conducting unannounced audits at the facilities in our foreign supply chain for that customer. The prohibition against slave labor and human trafficking is a major part of these audits. If non-compliance is found, we must work with the affected facility to bring it back into compliance. If they cannot, we must (and will) drop them as a supplier.

Certification. Mount Vernon has entered into Supplier Agreements with each of its foreign suppliers. These agreements include provisions committing the supplier to certify that it is in compliance with all applicable laws and regulations, such as those prohibiting human trafficking. These agreements further state that slave labor is not to be allowed in connection with any work for Mount Vernon. Mount Vernon follows up using the audits discussed above to ensure compliance with the agreement. In many cases, the supplier also has to make certification to our customers that it is not using slave labor.

Internal Accountability. Issues like human trafficking are very important to Mount Vernon. Making sure that Mount Vernon does not use suppliers that engage in human trafficking is the responsibility of the Corporate Vice President & Secretary. Company inspectors report on compliance issues (such as the slave labor prohibition) to their managers, who in turn provide status reports to the Corporate Vice President & Secretary. Also, all employees are encouraged to bring compliance issues they discover to the attention of the Corporate Vice President & Secretary. Mount Vernon maintains an “open door” policy so these matters can be reported. The Corporate Vice President & Secretary makes the final determination on responsive action in event of refusal to comply, including termination of the supplier and notification of local authorities where appropriate.

Training. The Corporate Vice President & Secretary regularly meets with Mount Vernon managers and employees who work with foreign suppliers to discuss compliance issues. The Corporate Vice President & Secretary also regularly meets with the particular Mount Vernon managers with responsibility for foreign supplier compliance, to ensure they understand their role in identifying, assessing and managing compliance issues such as the slave labor prohibition.

Compliance with all applicable laws and regulations is an important, on-going activity for Mount Vernon. This page will be updated as circumstances warrant. For more information, please contact us at 864-688-7100.



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