CTSCA Disclosure

Exxel Outdoors, LLC condemns the practices of human trafficking and slavery, and prohibits these activities from having any place in our supply chain.

Human trafficking is the "recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation."

- Definition by the International Labour Organization of the United Nations

The California Transparency in Supply Chains Act of 2010 (the “Act”) was enacted into law in an effort to eradicate human trafficking and slavery worldwide. California consumers are urging companies to provide greater transparency about goods brought to market in order to make responsible purchasing decisions. The Act requires large retailers and manufacturers to disclose on their websites “efforts to eradicate slavery and human trafficking from their direct supply chains”. Policies and processes to identify and prevent unethical recruitment of workers and promote fair treatment of employees in product supply chains is vital to overcome this worldwide labor concern.

The following disclosure statement describes how we oversee our supply chains for continued compliance to our policies against slavery and human trafficking:

Exxel Outdoors, LLC and its subsidiaries have implemented a corporate wide social responsibility program to ensure ethical business principles and policies, based upon our Code of Conduct, direct all sourcing decisions. We operate in accordance with all applicable laws and regulations, while seeking to improve working conditions and safeguarding human rights where ever our apparel and equipment is manufactured. Exxel’s commitment is to not work with facilities that engage in human trafficking and/or slavery, considering it a zero tolerance violation. When evaluating vendor performance, social responsibility is as important a parameter as quality, value, and delivery. Our stakeholders, including customers, employees, and the general public rely on Exxel to demonstrate a viable and sustainable social compliance program. We take the responsibility seriously and strictly enforce our Code of Conduct.

• Demonstrate high Ethical Standards
• Operate within legal Working Hour requirements
• Provide all legal Wages and Benefits
• Employ no Child Labor with Age Documentation of all workers
• Practice Environmental Safekeeping
• Assure Health and Safety for both factory complex and dormitories
• Abide by Legal Requirements of Country law
• Employ no Prison or Forced Labor
• Engage in Non-Discriminatory Policies
• Maintain acceptable forms of Disciplinary Practices
• Promote Legal Rights to Freedom of Association

Exxel employs an internal audit staff and contracts with independent third-party monitors for rigorous social compliance audits of all factories, usually on an announced basis.The scope of audits requires factories to provide detailed records including employment recruitment method, age verification, payroll and time data, worker benefits, and production records to validate compliance. Confidential worker interviews are conducted to ascertain the employee’s point of view for any evidence of harassment or abuse, compulsory labor, or human rights concerns.

A company Vendor Manual, outlining policies, specific social compliance criteria, and monitoring expectations is issued to all Suppliers annually. Supplier’s signature, to acknowledge, accept and adhere to our policies and to the laws and regulations in the jurisdiction where products are manufactured, is mandatory.

Company membership utilizing the collaborative resources of Fair Factories Clearinghouse (FFC) is a valuable database tool for tracking and analysis of compliance efforts. Together with other textile industry leaders as members, the FFC is dedicated to improving workplace conditions internationally. Additionally, factory ratings established within FFC provide a vital control point to prevent issuance of purchase orders unless compliance practice and audit result are found to be at acceptable levels. Control of this internal process is assigned to our compliance manager to assure accountability and prohibit production at unauthorized factories.

Company policy requires our Code of Conduct to be prominently displayed in all factories, in the local language, for all workers to view. We encourage Suppliers to attend training or educational events which promote best practices in employment methods and social responsibility. Our internal audit team will train, guide, and recommend solutions during periodic factory assessments.

Exxel and its divisions are proud of the history behind our Social Responsibility program. Exxel’s subsidiary, American Recreation Products, instituted a Code of Conduct in 1995, with continuous monitoring efforts throughout two decades. Exxel requires this Code of Conduct to be actively implemented by all the factories we contract. Dignity and ethical treatment of all factory employees who manufacture our products is the core objective. The program’s effectiveness is based on vigilant enforcement, understanding unique factory operations, and encouraging supplier management to enable process improvements affecting the worker’s quality of life.