California Transparency Act

California Transparency in Supply Chains Act of 2010

As a retail seller doing business in the state of California, we are required to provide you with details of our efforts to address the issue of slave labor and human trafficking in our supply chain.

Lands' End, Inc. has a Global Compliance Program to ensure that suppliers for Lands' End and its Subsidiaries comply with applicable local laws as well as Lands' End internal standards related to child labor, wages and benefits, working hours, harassment/abuse, discrimination, health and safety, factory security, freedom of association, environmental compliance, and forced/slave labor, human trafficking.

A summary of specific efforts from the Lands' End Global Compliance Program includes:

• Supplier Requirements. Suppliers who produce merchandise for Lands' End or its subsidiaries are provided and expected to adhere to the Global Compliance guidebook to Program Requirements, which outlines our expectations pertaining to social compliance, including slave labor and human trafficking.
• Supplier Audits. Factories that produce our merchandise are audited when we believe there is high risk for slave labor and human trafficking. The audits are conducted by approved 3rd party audit firms on our behalf. All auditors are trained to understand our Program, our expectations, and the specific local language and laws in each country. The audits are conducted on site, and involve discussions with workers, management interviews, a review of pertinent factory records, and a physical inspection of the factory and dormitory. After the audit, any violations of our standards are documented, and a detailed corrective action plan is required. Regular follow-up visits are also conducted to ensure efforts are made to correct any violations.
• Supplier Training. We provide our vendors annual training to review and reinforce our Global Compliance Program Requirements in detail. Our training specifically reviews our Requirements related to slave labor and human trafficking, and how to identify high risk situations and potential non-compliance. As further reinforcement of our training, in December of 2011, we issued a notification to all of our merchandise suppliers outlining our policy related to the California Transparency in Supply Chains Act of 2010, and our right to terminate a supplier if violations related to slave labor or human trafficking are cited.
• Internal Training. Training on all Program Requirements is provided by our lead audit firm to all 3rd party audit firms who conduct social compliance audits on our behalf. In addition, Lands' End employees who visit factories as part of their job responsibilities are made aware of the indicators of slave labor and human trafficking, and are required to report any potential issues for further investigation.

For more information regarding Lands' End's efforts to address the issue of slave labor and human trafficking in our supply chain, you may email compliance@landsend.com