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California Transparency in Supply Chains Act

Conducting business in a responsible manner is important to Harry and David, LLC and its affiliated companies. We require our business suppliers to comply with the applicable laws of the United States and those of the respective country of manufacture or exportation, including, without limitation, those laws addressing slavery and human trafficking.

As part of our supplier oversight, we have taken the following steps to combat slavery and human trafficking in our direct supply chain:

• Most new suppliers are required, as part of the supplier qualification process, to agree to our established policy that contains prohibitions on forced labor and child labor, and requires, among other things, compliance with applicable laws and regulations relating to working hours, wages and benefits, non-discrimination, working conditions and working environment. Such suppliers that fail to comply with the policy are subject to termination. Additionally, our standard Purchase Order Terms and Conditions require a supplier’s compliance with all applicable federal, state, provincial and local laws, statutes, treaties and regulations (including, without limitation, those relating to labor, health and safety) with respect to the production of the products covered by the P.O.
• Our standard Purchase Order Terms and Conditions further require that a supplier allow our representatives (including, potentially, independent third parties), during the term of the P.O. and for up to one year after the supplier’s performance under the P.O., and upon notice, to audit the supplier’s facilities, records and business practices in order for us to verify the supplier’s compliance with our requirements under the P.O.
• We require our employees to strive to achieve and maintain our high standard of ethical business practices. Employees who fail to comply may be subject to disciplinary action, up to and including termination.

Social responsibility at Harry and David, LLC is an on-going process. As we continue to review our standards, procedures and policies, we work with our employees and suppliers to add improvements. As part of that process, we anticipate working on the following initiatives:

• Expanding our supply qualification process so that all suppliers understand and adopt our established policy of compliance with all applicable laws in producing products we purchase;
• Developing training for employees and management who are directly responsible for managing supply chains on mitigating risks of slavery and trafficking;
• Initiating a verification process that will help us to further evaluate and address risks of slavery and human trafficking in our direct supply chains;
• Requiring direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking.