California Transparency in Supply Chains Act

The California Supply Chains Act of 2010 (SB-657) (the “Act”) went into effect on January 1, 2012. This law requires certain retailers and other businesses doing business in California to disclose to the public their efforts, if any, to ensure that the goods they sell are not made by workers who are enslaved, or otherwise forced into service, or who have been the victims of human trafficking.

Birchbox does not condone or intentionally support human trafficking, slavery or any other form of forced labor. To address the specific requirements of the Act, we are disclosing the following information:

Verification

Birchbox personnel conduct periodic site visits at its third-party warehouse and fulfillment center to observe operations. Birchbox does not otherwise currently engage in any direct verification of its product supply chain to evaluate and address risks of human trafficking and slavery. Birchbox is committed to complying with all laws applicable to its operations, including any and all laws regarding slavery and human trafficking, and requires that each of its suppliers, including its brand partners, do the same, via contractual obligations.

Audits

Birchbox does not presently conduct audits of its suppliers with respect to slavery or human trafficking. However, we continue to evaluate the feasibility of conducting audits, or engaging a third party to do so.

Certification

Aside from contractual representations and warranties regarding compliance with all applicable laws, rules and regulations, including those relating to human trafficking and forced labor, Birchbox does not currently require its suppliers to provide any additional certification regarding compliance with slavery and human trafficking laws.

Internal Accountability

Birchbox’s employee code of conduct requires each employee to act in accordance with the highest standards of business ethics, which includes a requirement that each employee comply with all laws and regulations applicable to Birchbox. While our code of conduct does not make a specific reference to human trafficking or forced labor, we consider our requirements that each employee comply with the law and conduct business in a fair and open manner with the highest regard for our customers, our community and each other as including a prohibition against human trafficking, coerced labor and slavery. An employee’s failure to comply with the code may result in disciplinary action, up to and including termination of employment.

Training

Birchbox does not currently provide any specific training for its personnel responsible for supply chain management with respect to human trafficking and slavery and methods for mitigating risks. However, Birchbox reviews all of its policies and procedures, including training practices, on a regular basis and will continue to consider the appropriateness of expanding its training offerings.

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