California Transparency in Supply Chains Act Disclosure 

JV Asset Holdco, LLC (“John Varvatos”) is committed to conducting business according to the highest ethical and legal standards. We operate under a Code of Business Conduct, which sets forth the key principles under which our company and our worldwide affiliates are required to operate.

John Varvatos also supports the California Transparency in Supply Chains Act of 2010 (SB 657) (the “CA Transparency Act”), which requires companies to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. We work hard to choose reputable business partners who operate in strict compliance with the California Transparency Act and who are committed to a set of ethical standards and business practices that are compatible with our Code of Business Conduct.

We require all of our manufacturers, contractors, suppliers, licensees and agents to comply with our Terms of Engagement and Global Compliance Principles (the “Principles”) and to verify that any subcontractors they use in connection with John Varvatos products also comply with the Principles. These Principles include ethical labor standards which prohibit the use of involuntary or forced labor, indentured, bonded or otherwise, among other unethical labor practices. We require each factory to maintain documentation necessary to demonstrate compliance with the Principles, and to grant us access to all records, including confidential interviews with employees. The Principles require each factory to create an informed workplace, by educating employees, and communications and prominent posting of the standards, translated into the language of the employees, throughout the workplace.

We engage in verification of our product supply chains, by both internal and third-party auditors, to evaluate and address risks of human trafficking and slavery. Our suppliers are cleared and vetted prior to selection. We are dedicated to improving workplaces around the globe, and ensuring informed, ethical business transactions. To that end, we participate in an industry-wide shared database of factories committed to our values and principles, the Fair Factories Clearinghouse.

We conduct internal audits of our suppliers to evaluate their compliance with our Principles, including our company standards against trafficking and slavery in supply chains. In addition, we retain multiple third party audit companies to assist us in meeting our goal of auditing each facility in our direct supply chain. Most of the audits are announced. A small percentage of the audits are unannounced. We provide audit results to factory managers who are required to sign and acknowledge them at the time of the audit. We require our suppliers to correct any problems identified by the audit, or face termination. Certain audit findings, such as the use of child labor, result in the immediate termination of that supplier with no opportunity to correct.

We require all of our suppliers, manufacturers, subcontractors, licensees and facilities that produce goods for John Varvatos to certify that they will not use involuntary or forced labor in the production of our products (or components thereof) and that they will take steps to prevent practices that could contribute to human trafficking.

We maintain internal accountability standards and procedures for employees and contractors failing to meet these standards regarding slavery and trafficking. We require all officers and employees of our company to adhere to our Code of Business Conduct. We provide each officer and employee is provided a copy of the Code of Conduct and asked to read it, understand it and follow it in their daily activities. Employees must sign an acknowledgement form that they have read the Code and certify and affirm that they will adhere to the Code. We conduct joint training with our buying agents and our direct factory suppliers in all our jurisdictions annually. We plan to include in our annual employee training program for all employees with supply chain responsibilities training with respect to mitigating the risk of human trafficking and slavery within the supply chain.

To ensure compliance with our Principles, we require facilities to maintain onsite all documentation necessary to demonstrate compliance with our Principles. We also require our manufacturers and direct suppliers to certify that they have in effect a program of monitoring their subcontractors to verify and ensure their compliance with these Principles. It is our policy to monitor every facility that is involved in the manufacture of a John Varvatos branded product, including apparel, non-apparel, cutting, sewing, screen printing, embroidering, laundering, packaging and raw material plants and facilities, as well as housing and residential facilities. Such inspections may be conducted by John Varvatos, one of its affiliates or representatives or an accredited audit company.

It has been and will continue to be our policy to obey the laws of each country and to honor our obligations to society by being an economic, intellectual and social asset to each community and nation in which we operate.