Disclosure Statement for California Transparency in Supply Chains Act

The Sportsman's Guide and its various brands and affiliates have had a longstanding commitment to observing the provisions of the United Nations International Labour Organization and that organization's principles aimed at eliminating child labor and abolishing slavery and forced or compulsory labor.

Suppliers of The Sportsman's Guide and its affiliates commit to the Supplier's Code of Conduct as a condition of doing business with us. The Code requires the suppliers to commit themselves to fundamental principles aimed at eliminating child labor, slavery, human trafficking and forced or compulsory labor.

More recently, California has passed the California Transparency in Supply Chains Act. That Act is designed to increase the information made available by retailers concerning their efforts to address the issues of slavery and human trafficking. In accordance with that Act, The Sportsman's Guide and its various brands and affiliates make the following disclosures.

As part of their commitment to eradicating slavery, human trafficking and forced labor, The Sportsman's Guide and its various brands and affiliates:

1. Verify product supply chains by using a third party company to ensure that the product supply chains are complying with the Code of Conduct and all applicable laws prohibiting slavery and forced labor.
2. Audit their suppliers to determine whether they are complying with the Code of Conduct and the applicable laws prohibiting slavery and forced labor. These audits are conducted by an independent third party company. These audits are semi-announced. The frequency of audits is based on the volume of business, country of origin, type of products, and evaluated risk with the suppliers.
3. Require their direct suppliers to comply with the Code of Conduct and the laws regarding slavery and human trafficking of the countries in which the suppliers are doing business.
4. Maintain an internal accountability record of the suppliers' compliance with the Code of Conduct. The Sportsman's Guide and affiliates generally reserve the right to terminate any supplier which fails to comply with applicable laws prohibiting slavery and human trafficking, subject to the opportunity to cure where appropriate.
5. Provide training for their sourcing team on the company policies designed to eliminate slavery and human trafficking and on the Code of Conduct and the need to include the Code of Conduct into any terms and conditions with suppliers.

As noted, The Sportsman's Guide and its affiliates have followed the principles of the International Labour Organization which include supporting the elimination of all forms of forced and compulsory labor and the effective abolition of child labor. Likewise, The Sportsman's Guide and its affiliates support the principles of the California Transparency and Supply Chains Act of 2010.