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California Transparency in Supply Chains Act Required Disclosure

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Onward Brands LLC, provides this statement pursuant to its obligations under the California Transparency in Supply Chains Act of 2010 (SB 657).

California Transparency in Supply Chains Act of 2010

The California Transparency in Supply Chains Act of 2010 is intended to provide public information from manufacturers regarding the activities they engage in to monitor their supply chains to prevent human trafficking and slavery. These disclosures allow businesses and consumers to make more informed decisions regarding the products they choose to purchase and the companies with whom they choose to conduct business.

Onward Brands is committed to conducting business only with suppliers who adhere to the highest ethical standards and comply with laws and regulations applicable to their business. Onward Brands has undertaken actions to ensure that the services and materials provided to Onward Brands meet this commitment.

Supplier Assessments and Qualification

Prior to engagement of a supplier, Onward Brands evaluates the supplier through a risk-based assessment. Such assessments may include supplier questionnaires and audits of supplier facilities. Onward Brands expects all potential suppliers to comply with the highest ethical and quality standards.

Supplier Performance Reviews

Onward Brands is committed to continuous improvement in its supply chain. Onward Brands and its suppliers monitor business performance through periodic evaluation and review of defined performance targets and objectives.

Supplier Audits

Onward Brands also regularly audits suppliers to confirm compliance with supplier performance and quality standards. Audits are performed by Onward Brands or third parties contracted by Onward Brands.

Supplier Agreements

Onward Brands has supply agreements, quality agreements and/or purchase order terms and conditions with all of its suppliers. These contracts include agreement to comply with all laws and regulations applicable to the supply of the service or material.

Employee Training and Compliance

All Onward Brands employees are required to comply with Incipio’s Corporate Social Responsibility Policy and all Onward Brands employees participate in annual training on the company’s Policy to ensure understanding and compliance with the requirements of the Policy. This training includes includes training on ethical decision making and upholding laws and regulations. In addition, Onward Brands maintains a compliance program that conducts regular audits of the requirements under the Policy, investigates potential violations of the Policy and takes disciplinary action when necessary.