Corporate Responsibility

California Transparency in Supply Chains Act of 2010 [SB 567]

The California Transparency in Supply Chains Act of 2010 (the "Act"), which takes effect on January 1, 2012, requires retailers and manufacturers doing business in the state of California to publicaly disclose their efforts to eradicate slavery and human trafficking from their supply chains. The Act seeks to provide the public with more accurate and accessible information about a company's human rights practices, so that consumers can make more informed decisions about the products they purchase and the brands they support.

C & J Clark America, Inc. ("Clarks") is committed to ensuring that our supply chain reflects Clarks' respect and concern for human rights. The following outlines the standards and procedures we have established, and the efforts we undertake, to prevent slavery and human trafficking within our direct supply chain:

Clarks Code of Practice: The Clarks Code of Practice sets forth a number of standards and requirements for all factories which manufacture products for Clarks. The Code of Practice addresses issues related to forced and child labor, wages, working hours, terms of employment, fair treatment and health & safety. In support of the Code of Practice we have defined critical standards that explicitly prohibit the use of forced, bonded, prison or child labor. The Code of Practice is based on factories meeting local legal requirements and internationally recognized standards as set out by the International Labour Organization (ILO). Suppliers are required to sign a copy of the Code to confirm their commitment to it. Compliance with our Code of Practice forms part of our trading terms and conditions with our suppliers.

Audit Procedures: Clarks operates an audit program to assure supplier compliance with our Code of Practice. The type, format and frequency of the audit is dependent on the product type and the source location. Audits are conducted either by trained Clarks' personnel or by the use of authorized third party auditors.

Employee Training: While our audit procedures are the main mechanism for ensuring that the standards set forth in our Code of Practice are upheld, Clarks also performs various trainings for employees with supply chain responsibilities. These trainings are intended to teach employees how to identify and respond to supply chain issues, including those involving forced or child labor. Clarks expects all employees to adhere to all applicable laws and regulations in the region of the world in which they work, and we provide a mechanism for employees to report any ethical violations they observe or become aware of.

Non-Compliance: Clarks does not tolerate forced labor, slavery, or human trafficking within our supply chain. We are committed to working with our suppliers to improve the working environment and conditions in factories. Suppliers who are determined to not meet critical standards within the Code of Practice and fail to take effective action to address non compliances will be eliminated from our supply chain accordingly. Employees who fail to uphold the standards set forth in our Code of Practice may be disciplined up to and including termination.

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C & J Clark America Inc., 156 Oak Street, Newton Upper Falls, MA 02464
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