CALIFORNIA TRANSPARENCY ACT

Introduction

Henry Milbourne & Son, Limited and its affiliates (collectively, “Henry Milbourne,” the “Company,” “we,” “us,” or “our”) support the goals of the California Transparency in Supply Chains Act of 2010 (the “Act”) and strive to be a model example of human rights and fair labor practices throughout our business activities. We choose the best suppliers in their field who provide premium quality in both their products and services but also by way of their ethical, social and environmental approaches and beliefs. To this end, we choose our suppliers based upon their ethics, honesty, and integrity in their business dealings, as well as the social and environmental principles by which they operate. The implementation of the Act presents the opportunity for us to reaffirm our commitment to enforcing measures that fight against slavery and human trafficking.

As a responsible corporate citizen, our actions in this area include the following:

Verification Requirements for Suppliers

Henry Milbourne has implemented a Code of Conduct (the “Code”) and requires all suppliers (including their subcontractors involved with the manufacturing process for our merchandise) to agree to and adhere to the terms of the Code. The Code sets forth and establishes non-negotiable minimum standards for our suppliers in the areas of health and safety, labor standards, business integrity, and the environment. In addition, we may conduct supplier audits, described below, in order to verify that our suppliers are complying with the Code.

Supplier Audits

We audit and will audit suppliers based upon an analysis of the volume of the supplier’s business and the risk of abuses in the country in which the supplier is located, pose a high risk of working condition violations to ensure that its suppliers are compliant with the Code.

Certification of Supplier Compliance

We require all suppliers to sign and to adhere to the Code.

Maintaining Accountability

In the event we become aware of any actions or conditions not in compliance with the Code, we reserve the right to demand corrective measures as well as the right to terminate an agreement with any supplier who does not comply with the Code.

Training to Company Employees

Henry Milbourne and its employees endeavor to respect the laws and regulations in all countries in which we operate, and conduct our business according to principles outlined in the International Labor Organization and the United Nations Universal Declaration of Human Rights.

Henry Milbourne will continue to evolve and adapt its policies and procedures to a changing world in order to reflect Henry Milbourne’s unwavering commitment to ethical business principles.