vineyard vines, LLC (“vineyard vines”) is committed to the responsibilities of fair labor practices, ethical business conduct, and legal compliance in all communities in which it does business. vineyard vines is concerned about Human Rights and expects its suppliers, contractors, subcontractors, agents, and subsidiaries and affiliated entities (each, a “Supplier”) to share its concerns.

This Supplier Code of Conduct applies to all Suppliers manufacturing and/or supplying goods for vineyard vines.

While vineyard vines recognizes that there are different legal and cultural environments in which our Suppliers operate throughout the world, these social compliance policies set forth the basic requirements that our Suppliers must meet in order to conduct business with vineyard vines. vineyard vines strongly encourages all Suppliers to exceed these policies in relation to legal compliance, fair labor practices, and ethical business conduct.

GENERAL EXPECTATION - It is expected that a Supplier will at all times act ethically and in full compliance with all applicable laws, rules, and regulations of the United States and those of the respective country of manufacture, operations, or exportation.

EMPLOYMENT RELATIONSHIP - vineyard vines is committed to safeguarding workers’ rights under both United States and international labor and social security laws and regulations. All Suppliers shall adopt and adhere to rules and conditions of employment that respect workers and, at a minimum, safeguard workers’ rights under applicable national and international labor and social security laws and regulations.

EMPLOYMENT AGE - No workers employed by the Supplier may be under the age of 15 or under the age for completion of compulsory education, whichever is higher. Supplier must observe all local guidelines and laws and requirements for work of employees under 18 years of age, particularly those pertaining to hours of work and working conditions.

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING - Supplier shall recognize and respect the right of employees to freely associate and collectively bargain, in accordance with applicable rules and regulations.

FORCED LABOR - Supplier warrants that the merchandise has been manufactured in compliance with the Uyghur Forced Labor Prevention Act and 19 USC §1307, which prohibits the importation of merchandise or its components made with forced labor, the International Labour Organization’s indicators of forced labor, and the Fair Labor Standards Act and rules and regulations thereunder.

Supplier also warrants that its merchandise has not been manufactured in contravention of any Withhold Release Order (“WRO”) issued by U.S. Customs and Border Protection (“CBP”).

Should CBP detain any shipment, Supplier acknowledges that it is vineyard vines decision whether to make a submission to CBP in order to obtain the release of the detained merchandise.

Should vineyard vines request traceability documents, Supplier warrants that it will submit requested documentation in a timely manner.

WAGES AND WORKING HOURS - A Supplier must always comply with all applicable laws, rules and regulations regarding wages and working hours in the locations in which it operates, including, but not limited to, all applicable laws, rules and regulations relating to minimum wage, time off and overtime compensation.

Supplier must ensure employees' hours worked shall not exceed the legal limitation on regular and overtime hours in the jurisdiction in which they operate.

HEALTH AND SAFETY - Supplier must always comply with all applicable health and safety laws, rules and regulations and provide a healthy and safe working environment that promotes accident prevention and minimizes exposure to health and safety risks. Suppliers should encourage employees to report all accidents, injuries, unsafe or hazardous working conditions and to alert management before performing tasks if the work is considered unsafe. Suppliers must also ensure that the same standards of health and safety are applied in any housing provided to employees.

DISCRIMINATION AND EQUAL OPPORTUNITY - Supplier must always comply with all applicable laws, rules and regulations concerning discrimination and equal opportunity in hiring and employment practices. The Supplier may not discriminate on the basis of race, color, national origin, ethnicity, age, gender, religion, sexual orientation, disability, or other similar factors.

HARASSMENT OR ABUSE - Supplier must treat all employees with respect and dignity. Supplier agrees it will not subject its employees to any form of corporal punishment, physical, sexual, psychological or verbal harassment or abuse at any time for any reason. Supplier should not use monetary fines as a disciplinary practice.

WOMEN'S RIGHTS - Supplier must ensure that female employees receive equal treatment in all aspects of their employment. A pregnancy test may not be a condition of employment. Employees should not be exposed to hazards that may endanger their reproductive health. No employee will be forced to use contraception.

DIVERSITY, EQUALITY, and INCLUSION - vineyard vines believes that diversity, equality and inclusion are social and economic imperatives and looks to its Suppliers to share this commitment in their operations, workforces and within their supply chains. Suppliers and their subcontractors are expected to engage a workforce that is inclusive of diverse groups. Suppliers are expected to take proactive steps to include the hiring of historically underrepresented groups, such examples are of workers who self-identify as minorities, ethnically diverse, women, LGBTQ+, Veteran, or a person with a disability. Suppliers should make commercially reasonable efforts to provide opportunities to a full spectrum of companies – based on the ownership structure (for example, disability-owned, LGBT-owned, ethnic minority-owned, veteran owned, women-owned), scale (for example, small enterprise) or nature of the enterprise (for example, social enterprise) – to compete on a fair and equal basis for their business.

ENVIRONMENTAL STANDARDS - Supplier must comply with all applicable local environmental laws and regulations. vineyard vines is committed to preserving the world’s natural resources. This includes implementing processes to identify and manage risks and opportunities related to climate change. Where appropriate to the size and nature of their operations, Suppliers should address the environmental impacts from its operations including raw material usage, greenhouse gas emissions, water, waste, air quality and biodiversity. Suppliers are encouraged to track, manage, and mitigate the environmental impact of their operations and strategies, including those of their suppliers. Where feasible, Suppliers should take steps to incorporate how they will mitigate the impact of climate change into their strategies and business resiliency plans, including establishing scope 1, 2 and 3 greenhouse gas (GHG) emissions reduction targets, and realizing these targets through efficiency measures, including selecting low GHG products and services, and other initiatives, where relevant and as applicable to their operations. If requested by vineyard vines, Suppliers are encouraged to disclose energy and GHG emissions management policies and performance. Suppliers are encouraged to take steps to conserve, reduce the use of, and reuse water in their own operations. Suppliers are also encouraged to manage water resources to ensure their operations do not prevent access to sufficient safe water, sanitation and hygiene for all users in surrounding communities, including those both up and downstream from their facilities. Suppliers are encouraged to take concrete steps to minimize or eliminate waste across their operations and those of their suppliers. Any waste, and in particular hazardous waste, must be managed in a responsible manner. Chemical and other materials posing a hazard if released to the environment should be identified and managed to ensure safe handling, movement, storage, recycling, reuse or disposal. All workers who handle waste and hazardous wastes must be properly trained on how to deal with substances and the potential hazards the material presents if mismanaged or released to the worker and environment. Suppliers must only use permitted transporters and haulers that have a positive record of operating safely and complying with applicable transportation laws and best management practices.

INSPECTION AND COMPLIANCE - Supplier will maintain on-site documentation as evidence of their compliance with the guidelines and policies expressed herein. vineyard vines will take affirmative measures, such as on-site inspections of the Supplier's facilities to ensure compliance. Supplier must allow vineyard vines representatives complete and full access to their facilities, as well as employee records, and employees for confidential interviews in connection with social compliance visits. Violation of these compliance guidelines and policies will be appropriately remedied at the cost of the Supplier.

BRIBES AND OTHER IMPROPER PAYMENTS - Supplier must never directly or indirectly offer, solicit, accept, make, promise, authorize, or provide any bribe, kickback or other improper payment or thing of value to any person or entity, including government officials or persons employed by a government or political party, in connection with any transaction or matter involving or relating to vineyard vines or any product it provides to vineyard vines. Supplier must certify that they are fully compliant with applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act, as well as local anti-bribery and anti-corruption laws.

ARRANGEMENTS AND RELATIONSHIPS - Supplier must not have any direct or indirect ownership, employment, consulting, financial or other arrangement or relationship with any vineyard vines director, officer, or employee that could potentially influence decisions related to the supplier or its products or otherwise give rise to a conflict of interest with vineyard vines.

CURRENCY CONTROLS AND MONEY LAUNDERING - Supplier must always comply with all applicable currency controls and never directly or indirectly participate in or cooperate with any money laundering scheme in connection with any matter involving or relating to vineyard vines.

CONFIDENTIAL INFORMATION - It is expected that Supplier will preserve and protect confidential information and will not permit any unauthorized disclosure or use of confidential information that it may receive or obtain or to which it may be given access in connection with its relationship with vineyard vines. Supplier should recognize that unauthorized use or disclosure of such information may have personal, legal, reputational and financial consequences for Supplier, the individuals whose personal information may be implicated, and for vineyard vines. In addition, Supplier must comply with all applicable privacy/data protection and information security laws and regulations.

COMPLIANCE - Supplier agrees to assist and cooperate in any investigation related to potential violations of this Supplier Code of Conduct.

Supplier is expected to adopt and carry out processes and procedures within its own organization that enable it to comply with this Supplier Code of Conduct.

Any violation of this Supplier Code of Conduct is to be reported to vineyard vines immediately upon discovery. Supplier must allow its employees to report violations of this Supplier Code of Conduct to vineyard vines without threat of retaliation or punishment.

If Supplier fails to comply with this Supplier Code of Conduct, vineyard vines shall have the right to wholly or partially suspend or terminate its relationship with Supplier and any or all outstanding purchase orders, contracts, and agreements without penalty, liability or obligation.

vineyard vines shall not be responsible for any delays or nonperformance caused by Supplier’s efforts to comply with this Supplier Code of Conduct.