DISCLOSURE UNDER THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers to disclose its efforts to eradicate slavery and human trafficking from its supply chain. Benefit is opposed to human trafficking and forced labor at any level, and we are committed to ensuring that the manufacturers and suppliers we work with meet our standards. Below are our required disclosures under the Act.

1. Benefit engages in verification of its product supply chains to evaluate and address risks of human trafficking and slavery. This verification is conducted through an audit by a Benefit Quality Assurance Manager, and/or by third parties.
2. Benefit conducts independent announced audits of its suppliers to evaluate their compliance with our standards for human trafficking and slavery. This audit is conducted on all new vendors that perform a service, manufacture product or manufacture any type of packing or collateral component for Benefit. All new vendors must pass the audit before business is awarded. Benefit also selects certain existing vendors to be subject to continued audits on a periodic basis. Benefit conducts these audits as an integral part of its quality assurance process, and uses a social accountability checklist that audits the supplier’s practices relating to child labor, forced labor, discrimination, wage and working conditions.
3. Benefit is in the process of requiring all suppliers to certify that materials incorporated into Benefit products comply with the laws regarding human trafficking and slavery of the country or countries in which the suppliers are doing business.
4. Benefit maintains internal accountability standards and procedures for contractors and suppliers failing to meet company standards regarding human trafficking and slavery. Specifically, Benefit’s audit procedures require each vendor to pass the social accountability audit in order to continue doing business with Benefit.
5. Benefit does not at this time provide company employees and management with specific training on human trafficking and slavery; however, Benefit is in the process of setting up mandatory training for all employees and management who have direct responsibility for supply chain management with respect to mitigating risks of human trafficking and slavery within our product supply chain.