CA SUPPLY CHAIN TRANSPARENCY

Everlane is committed to maintaining responsible and transparent practices throughout its global supply chain. We believe that safe working environments, fair treatment, respect for human rights, and responsible business conduct are essential to building long-term relationships with our suppliers and partners. As part of this commitment, we take steps to identify, evaluate, and address potential risks related to forced labor, child labor, human trafficking, and other labor-related concerns. Our supply chain practices are designed to support compliance with applicable laws and internationally recognized labor standards while encouraging continuous improvement among our business partners.

We conduct ongoing assessments of our direct suppliers to better understand social and labor conditions within the facilities where our products are made. Suppliers are required to provide information about their operations and employment practices before entering into a business relationship with us. This information may cover working hours, minimum worker age, disciplinary procedures, labor practices, and measures intended to prevent forced, involuntary, or otherwise unlawful labor. Reviewing these details at the beginning of a supplier relationship helps us identify potential concerns and evaluate whether a prospective partner meets our expectations.

Our supplier standards are communicated through a Vendor Code of Conduct that outlines expectations concerning responsible employment practices and compliance with applicable labor requirements. Direct suppliers are expected to make these standards available to workers in an appropriate and accessible manner. The requirements address important areas such as forced labor, child labor, discrimination, worker treatment, health and safety, and disciplinary practices. We also work to extend awareness of these expectations beyond direct suppliers so that relevant materials and manufacturing partners throughout the supply chain understand the standards applicable to their participation in our business.

Independent assessments are an important part of our supply chain monitoring process. Direct suppliers are subject to regular compliance reviews conducted by qualified third-party auditing organizations. These assessments examine a range of areas, including labor practices, compensation, working hours, workplace and living conditions where applicable, health and safety procedures, environmental practices, management systems, and supporting documentation. Auditors may review payroll and attendance records to determine whether workers receive appropriate compensation and whether recorded hours and overtime are handled in accordance with applicable requirements.

In addition to scheduled compliance assessments, observational reviews may be conducted throughout the year. These reviews are intended to provide additional visibility into ordinary operating practices and can help identify conditions that may not be apparent during a formal assessment. Worker interviews may also form part of the review process. Discussions can be conducted individually or in groups and, where appropriate, in the local language so that workers have a meaningful opportunity to describe their experiences and raise concerns about workplace conditions.

When an assessment identifies a deficiency, appropriate corrective measures may be required. Corrective Action Plans can be used to document identified issues, establish expectations for improvement, and provide a framework for suppliers to address weaknesses in their systems or procedures. We view remediation and continuous improvement as important components of responsible supply chain management. Members of our internal supply chain organization may also participate in supplier assessments and worker discussions to strengthen our understanding of conditions at production facilities.

We maintain a strong expectation that suppliers comply with applicable labor and human rights laws. Our supplier standards emphasize that businesses involved in producing or supplying materials for our products must take appropriate steps to prevent forced labor, human trafficking, child labor, discrimination, and other prohibited employment practices. We communicate these expectations to relevant suppliers and partners and seek to promote accountability throughout the supply chain rather than limiting responsibility to direct manufacturing relationships.

Internal accountability is another important element of our approach. Our teams are expected to consider ethical conduct and responsible sourcing when making decisions involving suppliers and supply chain operations. We maintain a zero-tolerance approach toward serious labor-related violations, including circumstances involving forced labor or human trafficking. Where significant non-compliance is identified, we may take decisive action, including ending a supplier relationship when appropriate. We recognize that effective prevention requires cooperation between our organization and the companies with which we work, and we expect suppliers to actively participate in addressing identified risks.

Training and education support our ability to recognize and respond to potential supply chain risks. Employees whose responsibilities involve product development, sourcing, compliance, or supply chain management may receive training concerning forced labor, human trafficking, child labor, and related human rights issues. Team members are encouraged to remain informed about developments in supply chain standards and emerging labor risks. Training can also help employees understand how to identify potentially high-risk situations, document concerns, escalate issues internally, and determine appropriate next steps when potential violations are discovered.

We also recognize that responsible supply chain management is an ongoing process rather than a single review or certification exercise. Conditions, regulations, supplier relationships, and potential risks can change over time. For that reason, we continue to evaluate our processes, engage with relevant suppliers, participate in industry education, and work with appropriate external organizations to strengthen our understanding of labor and human rights issues across the supply chain.

Our approach is intended to support transparency, accountability, and continuous improvement while reducing the risk that products or materials are connected to forced labor, human trafficking, or child labor. We expect our business partners to share these principles and to cooperate with monitoring, assessment, corrective action, and training activities when required.

Our supply chain transparency efforts also take into consideration applicable legislation in the jurisdictions where we conduct business. We support the objectives of laws designed to increase corporate transparency and encourage businesses to identify and address forced labor and child labor risks within their supply chains. In accordance with applicable Canadian requirements concerning forced labor and child labor in supply chains, we also prepare and maintain disclosures addressing the measures taken to assess and manage these risks.

Through supplier standards, third-party assessments, internal oversight, corrective action processes, employee education, and continued engagement with supply chain partners, we seek to promote responsible working conditions and respect for fundamental human rights throughout our operations. We remain committed to reviewing and improving these practices as our supply chain develops and as expectations surrounding ethical sourcing, labor protection, and supply chain transparency continue to evolve.