California Transparency in Supply Chains Act of 2010

S. Lichtenberg & Co. engages in the verification of our product supply chain to evaluate and address risks of human trafficking and slavery. We inspect and audit companies with whom we do business on a regular basis. Inspections are conducted by both our own personnel and independent third parties and include regular unannounced inspections.

S. Lichtenberg & Co. requires all direct suppliers to certify that the materials incorporated into the products they produce for us comply with the laws regarding slavery and human trafficking of the countries in which they operate.

As part of the terms and conditions of all purchase orders and contracts that we place, S. Lichtenberg & Co. requires suppliers to comply with all applicable US laws and regulations, including those relating to human trafficking and slavery. It is S. Lichtenberg’s policy to terminate our business relationship with any company found engaging in human trafficking, slavery or child labor.

S. Lichtenberg & Co. provides appropriate training for employees who have responsibility over supply chain management with respect to mitigating risks of human trafficking and slavery.

The following is a summary of S. Lichtenberg & Co.’s ethical standards policies:

S. Lichtenberg & Co. requires all factories and facilities from which we purchase goods to comply with basic ethical standards. We require independent certification of compliance either for our own account or in conjunction with the retailer to whom we sell your goods.

A summary of these standards follows:

· Child Labor: No workers under the age of 15, or the legally mandated minimum age, whichever is greater. Please note that we will terminate our relationship in the event of a violation of child labor laws.

· Forced Labor: No forced labor, including prison or debt bondage labor. As with the Child Labor provision, please note that violation of this policy will result in the termination of our business relationship.

· Health and Safety: We expect all factories to provide a safe and healthy work environment, and to take steps to prevent injuries. Factories should have policies in place for regular health and safety training. Factory management should be aware of and have a system to detect threats potential health and safety issues. Workers must have access to bathrooms and potable water.

· Freedom of Association and Right to Collective Bargaining: We expect factories to respect the rights of workers to form and join trade unions and bargain collectively as permitted by local law.

· Discrimination: No discrimination based on race, caste, origin, religion, disability, gender, sexual orientation, union or political affiliation, or age; no sexual harassment.

· Discipline: No corporal punishment, mental or physical coercion or verbal abuse.

· Working Hours and Compensation: We expect factories to comply with applicable local laws regarding working hours with overtime paid at a premium rate and not to exceed 12 hours per week on a regular basis. Wages paid for a standard work week must meet legal and industry standards and be sufficient to meet the basic need of workers and their families. Facilities must maintain accurate records documenting hours worked and compensation paid.

· Labeling – Items purchased must be labeled in accordance with US law and must accurately reflect country of origin and fiber contents.