California Transparency in Supply Chains Act

Express is dedicated to eliminating human trafficking and forced labor on all levels of our supply chain. Below are the steps Express is taking in furtherance of this goal.

1. Supply Chain Verification. Our list of qualified suppliers and factories is established and maintained in reliance on specific qualification standards and protocols developed by us, in conjunction with our independent third party service provider, which specializes in supply chain compliance. First, our sourcing process includes a supplier verification procedure designed to ensure that we work only with suppliers who are committed to meeting our supply chain standards. Once a supplier is verified, the relationship begins with a written Master Sourcing Agreement (MSA) wherein the supplier agrees that it and the factories that it contracts with will adhere to our sourcing and labor standards, including those prohibiting slavery and human trafficking.

2. Audit Procedures. Each supplier that we verify must agree to allow us, or an independent third party hired by us through our independent service provider, to conduct an audit of the supplier’s business unannounced, without prior notice, to ensure compliance with our human trafficking and forced labor standards. Generally, a third party conducts announced or unannounced audits of each of our approved factories at least annually to ensure compliance. We, through our third party service provider, may conduct more frequent reviews of suppliers located in countries designated as high risk by the U.S. State Department’s Trafficking In Persons Report. Exemptions from annual audits may be granted to highly compliant factories based on the previous year’s audit scores.

3. Supplier Certification. Each supplier is required to sign an MSA in which they agree that they will comply with our Supplier Code of Conduct. The Supplier Code of Conduct requires our suppliers to comply with all applicable laws and policies, including prohibitions against child labor and forced labor.

4. Internal Accountability. Express will not work with those who are unable or unwilling to meet our standards. We maintain policies and procedures which govern the consequences of non-compliance by associates or suppliers. Suppliers are informed of these policies and procedures and the consequences of non-compliance through receipt of a compliance guidebook. If any one of our suppliers falls below the standards listed in our Supplier Code of Conduct, we attempt to bring them into compliance by supporting them in making the necessary changes through corrective action plans.

5. Training. We are committed to supplier and associate education. Our third party service provider conducts annual awareness and training sessions for our suppliers on our sourcing standards in multiple countries around the world. In addition, our third party service provider engages in one-on-one training in conjunction with routine audits and corrective action plans. Also, we assure that our associates fully understand and comply with our sourcing policies and procedures. Associates directly involved in supply chain management receive training on human trafficking that discusses the risks of human trafficking and actions that can be taken to mitigate the risk of human trafficking.

6. Collaboration. We are committed to collaborating with others to eradicate human trafficking and support the work of international agencies and organizations dedicated to this cause. In 2015, we made a donation to the MGF Touch Foundation to support their work to prevent and end human trafficking.