California’s Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California to disclose efforts taken to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale, giving consumers additional criteria to make buying decisions.

EMS considers its reputation for integrity and fairness to be one of its most valuable assets. EMS expects its team members and supply chain vendors to comply in all respects with applicable laws and regulations in each governing jurisdiction that it does business. Supply chain vendors execute Master Supplier Agreements (“Agreements”) with EMS in which they take the following actions:

1. Warrant that EMS products do not violate any laws, ordinances, statutes, rules, or regulations, which include compliance with laws respecting the eradication of slavery and human trafficking
2. Acknowledge that slavery and human trafficking is not involved in the manufacture or sale of EMS products
3. Acknowledge that EMS supports the eradication of slavery and human trafficking from supply chains and seeks to partner with supplier partners who share the same policies and practices
4. Conduct an annual or semi-annual audit on EMS products in order to regularly confirm that slavery and human trafficking does not play a part in the manufacture or sale of these products

These Agreements create an affirmative obligation on the part of EMS supply chain vendors to promptly provide notice of violation of any such laws, ordinances, statutes, rules, or regulations. The Agreements also require EMS supply chain vendors to be accountable for any violations of law by providing the company indemnification for violations relating to its products. Agreements and certifications are updated on a periodic basis.

Team members may report violations of the Code through anonymous reporting to an independent third party. EMS has communicated to its supply chain vendors that the Company supports efforts to eradicate slavery and human trafficking from supply chains, and their acknowledgment that their products are not manufactured and supplied in a manner inconsistent with those efforts. Annual training has been implemented for internal employees with direct responsibility for supply chain management. EMS reserves the right to make periodic, unannounced audits of its supply chain vendors’ facilities for compliance with the requirements of these Agreements, including compliance with laws, ordinances, statutes, rules, and regulations. EMS reserves the right to remove supply chain vendors from the supply chain for non-compliance with these Agreements. EMS does not utilize a third party for verification or unannounced audits at this time, but reserves the right to do so in the future.

EMS does not manufacture any products sold in the company’s retail locations. For more information about the slavery and human trafficking eradication policies of EMS branded-label supply chains, please visit their respective websites.