California Transparency In Supply Chains Act Of 2010

SECURITY

September 30, 2010, the Governor of the State of California approved the California Transparency in Supply Chains Act of 2010 (the "Act"), which requires companies to disclose the efforts they have made and measures they have implemented to eradicate slavery and human trafficking from their respective supply chains. In doing so, the Act is designed to help consumers seek and purchase products from companies that "responsibly manage their supply chains," which in turn will "improve the lives of victims of slavery and human trafficking."

Brooks Bingham Clothing Inc. is committed to purchasing products only from direct suppliers that adhere strictly to our CODE OF CONDUCT. In addition to the general requirement that our direct suppliers are in compliance with any and all applicable laws of the jurisdictions in which they are doing business (including any and all laws relating to slavery and human trafficking), our Code of Conduct explicitly and strictly prohibits forced labor and child labor of any kind.

Brooks Bingham Clothing Inc. HAS ZERO TOLERANCE FOR SLAVERY AND HUMAN TRAFFICKING AND MAKES THE FOLLOWING EFFORTS IN FURTHERANCE OF SUCH POLICY:

Brooks Bingham Clothing regularly examines its product supply chain to uphold its commitment to work only with suppliers that strictly comply with our Code of Conduct. The examination process begins with an in-depth, on-site initial evaluation of potential new suppliers conducted by appropriate Brooks Bingham Clothing Inc. personnel. Following our initial assessment, we engage an independent third-party auditing firm to audit such potential new supplier's social compliance practices.

For nearly all direct suppliers with whom we do business, we verify their respective compliance with our Code of Conduct by conducting announced, on-site audits of their respective operations. Such audits are conducted either by Brooks Bingham Clothing or an independent third party audit firm.

Each of Brooks Bingham Clothing Inc.' direct suppliers is required to execute a Compliance Agreement certifying that all of its products to be purchased by Brooks Bingham Clothing will be manufactured in accordance with our Code of Conduct, which, as noted above, requires compliance with any and all applicable laws relating to the production of such products (including any and all laws relating to slavery and human trafficking).

Brooks Bingham Clothing Inc maintains and enforces internal accountability procedures for employees and contractors regarding company standards in slavery and human trafficking. In the event of non-compliance by an employee or contractor, Brooks Bingham Clothing takes any and all actions it deems appropriate, up to and including termination of such employee or contractor.

Through ongoing internal training and educational efforts, as well as constant encouragement to attend external social compliance seminars, Brooks Bingham Clothing strives to keep the appropriate personnel, including those in its sourcing, production, and legal departments, knowledgeable on and attentive to social compliance concerns such as human trafficking and slavery abuses.

WORKPLACE CODE OF CONDUCT

At Brooks Bingham Clothing Inc. we are committed to:

a standard of excellence in every aspect of our business and every corner of the world;

ethical and responsible conduct in all of our operations; and

respect for the rights of all individuals.

We expect these same commitments to be shared by all Suppliers that have a hand in the sourcing and manufacture of Br’ merchandise. In the selection of our Suppliers, Brooks Bingham Clothing works diligently to choose reputable Business Partners who are committed to ethical standards and business practices compatible with those of Brooks Bingham Clothing I, helping us to ensure that Brooks Bingham Clothing’ products are produced under safe, lawful, humane and ethical conditions.

While Brooks Bingham Clothing recognizes that our Suppliers operate in diverse legal, and cultural environments throughout the world, the following code of conduct (the “Code of Conduct”) sets forth the basic minimum requirements all Suppliers must meet to do business with Brooks Bingham Clothing:

Laws and Regulations - Suppliers shall comply with any and all legal requirements applicable to the operation of their businesses.

Forced Labor – Suppliers shall not use forced labor, whether in the form of prison, indentured, bonded, slave or human trafficked labor.

Child Labor – Suppliers shall not employ any workers who are younger than the age permitted by applicable law.

Harassment or Abuse - Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment or ill-treatment. Additionally, Suppliers shall not use monetary fines as a form of discipline.

Nondiscrimination – Suppliers shall ensure that no person shall be subject to any discrimination in employment, including hiring, salary, benefits, advancements, discipline, termination or retirement by gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.

Women’s Rights – Suppliers, shall ensure female workers receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment, and pregnancy testing – to the extent provided – will be voluntary and the option of the worker. Also, workers will not be forced to use contraception.

Health and Safety - Suppliers shall provide a safe, healthy and clean working environment that is in compliance with applicable national and local laws to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of their respective facilities..

Freedom of Association and Collective Bargaining - Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining as may be allowed by law.

Wages and Benefits - Suppliers shall recognize that wages are essential to meeting employees' basic needs. Suppliers shall pay employees, as a floor, at least the minimum wage - including appropriate compensation for overtime hours, if applicable - required by local law. Suppliers shall provide all legally mandated benefits.

Hours of Work - Suppliers shall ensure that, except in extraordinary business circumstances, on a regularly scheduled basis, workers shall not be required to work more than the lesser of (a) sixty (60) hours per week, including overtime and (b) the limits on regular and overtime hours allowed by the law of the country of manufacture. Also, except in extraordinary business circumstances, all workers shall be entitled to at least one day off in every consecutive seven (7) day period.

Environment – Suppliers shall comply with all local environmental laws and regulations applicable to the workplace.

Additionally, Suppliers are expected to conduct business in a manner which minimizes their impact on the environment.

Subcontracting – Suppliers must not use subcontractors in the manufacture of products or product components for Brooks Bingham Clothing without approval from Brooks Bingham Clothing, and only after the subcontractor has adequately demonstrated compliance with this Code of Conduct.

Communication – Suppliers shall communicate the provisions of this Code of Conduct to all of their respective workers and supervisors.

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