California Transparency in Supply Chains Act Disclosure

(in compliance with Cal. Civ. Code § 1714.43)

At Room & Board, we recognize the critical role we play in making quality home furnishings that improve the lives of our customers. Doing so in a sustainably and socially responsible way requires that we balance the social, environmental and economic benefits and risks of our products, including how they are sourced, manufactured and used.

Room & Board’s commitment to ensuring that its supply chain is managed in a socially responsible manner includes an expectation that suppliers not use forced labor in any of its forms, including human trafficking and slavery, to make the products they provide to Room & Board and its customers. These expectations are set out in the Room & Board Supplier Code of Conduct.

Room & Board utilizes a combination of supplier self-audits, Room & Board direct audits and third-party audits to ensure that suppliers are committed to the Supplier Code of Conduct and its requirements. In addition, Room & Board educates our Merchandising and Vendor Management teams within the organization on the Supplier Code of Conduct. This helps our employees educate our suppliers as well as ensures that our supply chain follows through on its commitment to being a good global partner.

Verification

Room & Board vendor procedures require suppliers to refrain from the direct or indirect use of forced labor or any form of human trafficking and certify compliance with this requirement. Room & Board also requests that its suppliers implement procedures to manage the materials, including all labor related processes, incorporated into their products to ensure compliance with laws on human trafficking and slavery.

Auditing

To evaluate supplier compliance with these standards against human trafficking and slavery in the supply chain, Room & Board asks its vendors for annual self-audits through our business review process in addition to subjecting vendors to random, unannounced audits either by a Room & Board employee or by an approved third-party audit firm.

Certification

Suppliers must also certify annually that the products they make do not directly or indirectly use any form of forced labor or human trafficking and that the supplier has procedures in place to manage the materials, including all labor related processes, incorporated into their products to ensure they comply with laws on human trafficking and slavery.

Internal Accountability

Room & Board requires all its employees to comply with applicable federal, state and international law. Any employee found to be in violation of any law prohibiting trafficking or slavery is subject to disciplinary action and termination. Contractors or suppliers violating Room & Board’s standards, including the prohibition against trafficking or slavery, are subject to investigation and appropriate action up to and including: termination of association and termination of agreements for supplies with the violating party.

Education and Training

Room & Board is committed to responsible and ethical sourcing for its merchandise and thus provides training to employees and decision makers involved in placing purchasing orders and selecting suppliers. These employees and decision makers are made aware of the impact of their decisions that can affect factory working conditions in other countries. These employees are educated and trained on the laws prohibiting human trafficking and slavery and the importance of selecting suppliers that comply with these laws.