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California Transparency in Supply Chains Act (SB 657)

General

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Verification

Perry Ellis International, Inc. ("PEI") assesses and verifies the risk of slavery and human trafficking in its supply chain. PEI conducts its risk assessment by country using the ranking system of the US Department of State's Annual Report on Human Rights and Human Trafficking located at http://www.state.gov/g/tip/rls/tiprpt/2011, wherein country-specific risk level assignments are based on a three-tier ranking of the local government's compliance with the Trafficking Victims Protection Act. Risk assessment is performed internally by PEI.

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Audit

PEI conducts audits of direct suppliers. PEI has developed and issued a Vendor Code of Conduct to its direct suppliers. Direct suppliers are evaluated on their compliance of our code through announced and unannounced audits conducted by PEI’s auditors and third party organizations.

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Certification

PEI manufacturing agreements require its suppliers to certify in writing that they comply with all applicable laws within the country of business including those regarding slavery and human trafficking as well as PEI’s Vendor Code of Conduct.

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Accountability

PEI maintains and enforces internal accountability procedures for employees and compliance by contractors regarding company standards on slavery and human trafficking. In case of non-compliance PEI reserves the right to examine the specific situation and develop a best possible strategy for resolution. If cases of non-compliance are not resolved within a timely manner, PEI may terminate the business relationship.

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Training

PEI conducts internal training on its Vendor Code of Conduct to ensure the necessary participants in the supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including human trafficking and slavery, with a particular focus on mitigating risks. PEI also encourages employees involved in PEI's supply chain to participate in external training programs and seminars on social compliance issues.

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