Ethical Supply Chain Disclosure Statement

ModCloth is made up of a compassionate group of people dedicated to having a net-positive effect on the world. With the utmost respect for internationally recognized human rights and environmental standards, it is committed to conducting business in a lawful and an ethical manner. Additionally, ModCloth expects its manufacturing and market vendors, who are considered Business Partners, to share this same commitment.

In Spring of 2013, ModCloth adopted Ethical Supply Chain Guidelines. These Guidelines set forth the requirements with which Business Partners must comply in order to continue to work with ModCloth. Pursuant to the California Transparency in Supply Chains Act, ModCloth discloses as follows.

Verification

ModCloth engages a qualified third-party to evaluate and address risks of human trafficking and slavery involving Business Partners which meet certain risk-related criteria.

Audits

ModCloth also engages the qualified third-party auditing firm to audit Business Partners to evaluate compliance with ModCloth's Ethical Supply Chain Guidelines. At this time, audits and inspections of these Partners are announced, however, ModCloth is investigating options to conduct unannounced audits in the future.

Certification

In order to do business with ModCloth, potential Business Partners must consent to follow our Ethical Supply Chain Guidelines and conduct business in compliance with applicable laws, including, among other things, without child labor, without forced or compulsory labor, without corporal punishment, without discrimination, and in compliance with wage and hour requirements, health and safety, and environmental laws.

Internal Accountability Standards

ModCloth maintains internal accountability standards. Should ModCloth find that a Business Partner is out of compliance with the Guidelines, ModCloth would assess the cause of the non-compliance and develop an action plan to assure future compliance. ModCloth will help Business Partners correct problems when they are found and build management systems that prevent problems from reoccurring. By working with Business Partners in this way, ModCloth can improve the lives of people who work for these Partners. However, should a Business Partner fail to comply with a remediation plan, or should a Business Partner commit a significant breach of the Guidelines, ModCloth may terminate its business relationship with the Partner.

Training

ModCloth employees who are responsible for supply chain management receive training to further develop their ability to identify and evaluate risks in the supply chain. This internal education of key staff sets ModCloth's foundation for fulfilling its commitment to having a net-positive effect on the world, starting from the inside out.

Thank you for supporting ModCloth's efforts on this important issue, and please stay tuned for ongoing updates.

Last updated: October 11, 2013

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