TRANSPARENCY ACT

THIS STATEMENT IS MADE PURSUANT TO, “THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010”, WHICH REQUIRES REGISTERED BUSINESSES CONDUCTING SALES IN CALIFORNIA TO DISCLOSE THEIR EFFORTS TO ERADICATE SLAVERY AND HUMAN TRAFFICKING IN THEIR DIRECT SUPPLY CHAIN. THIS STATEMENT SETS OUT THE STEPS TAKEN BY CODY COVERDELL SARL (“CODY COVERDELL LIMITED” OR “OUR”, RESPECTIVELY) TO ENSURE THAT SLAVERY, SERVITUDE, FORCED OR COMPULSORY LABOR, AND HUMAN TRAFFICKING (COLLECTIVELY, “MODERN SLAVERY”) IS NOT TAKING PLACE IN ANY PART OF ITS BUSINESS OR withIN ITS SUPPLY CHAINS.

CODY COVERDELL LIMITED PURCHASES FULFILLMENT GOODS, MARKETING, PACKAGING, AND POINT OF SALE MATERIALS FROM SUPPLIERS LOCATED IN SELECT EUROPEAN COUNTRIES, MOST NOTABLY FRANCE AND ITALY. CODY COVERDELL LIMITED DIRECTLY OR INDIRECTLY MANUFACTURES, DISTRIBUTES, AND SELLS LUXURY READY-TO-WEAR, HAUTE COUTURE, FOOTWEAR, HANDBAGS, AND JEWELRY UNDER THE TRADEMARKS “CODY COVERDELL” OR “CODY COVERDELL PARIS”. OUR MAISON’S COMMITMENT IS TO ACT WITH INTEGRITY IN ALL ITS BUSINESS DEALINGS AND TO PROMOTE ETHICAL PRACTICES TO ENHANCE COMPLIANCE WITH APPLICABLE LAW AND TO PROVIDE GUIDANCE WITH RESPECT TO BUSINESS CONDUCT. CODY COVERDELL LIMITED HAS A NUMBER OF POLICIES THAT ARE RELEVANT TO THIS COMMITMENT, WHICH SET OUT WHAT CODY COVERDELL LIMITED EXPECTS FROM ITS CONTRACTORS, INTERNAL BUSINESS PARTNERS, AND EXTERNAL SUPPLIERS.

CODY COVERDELL LIMITED EXPECTS ITS CONTRACTORS AND SUPPLIERS TO SHARE ITS COMMITMENTS AND TO ACT IN FULL COMPLIANCE WITH ALL APPLICABLE LAWS, INCLUDING ALL LOCAL, NATIONAL, AND INTERNATIONAL LAWS RELATING TO THE MANAGEMENT OF THE APPAREL INDUSTRY. CODY COVERDELL LIMITED REQUIRES ITS CONTRACTORS AND SUPPLIERS TO SEEK APPROVAL BEFORE SUBCONTRACTING ANY PART OF THEIR SUPPLY CHAIN PROCESS AND OUR MAISON’S APPROVAL IS SUBJECT TO ACCEPTANCE BY THE SUBCONTRACTOR OF THE SUPPLIERS’ CODE OF CONDUCT AND SUCH OTHER CONDITIONS THAT CODY COVERDELL LIMITED DETERMINES.

THE CODY COVERDELL LIMITED CODE OF CONDUCT INCLUDES RELEVANT SECTIONS ON “HONESTY AND ETHICAL CONDUCT”, “COMPLIANCE WITH LAWS AND REGULATIONS”, “SAFE WORKING CONDITIONS”, AND “SALES AND COMMERCIAL TRANSACTIONS”. OUR MAISON’S ANTI-MODERN SLAVERY POLICY REFLECTS A COMMITMENT TO ACT ETHICALLY AND WITH INTEGRITY IN ALL RELEVANT BUSINESS RELATIONSHIPS AND TO BOTH IMPLEMENT AND ENFORCE EFFECTIVE CONTROL SYSTEMS TO ENSURE SLAVERY AND HUMAN TRAFFICKING ARE NOT TAKING PLACE ANYWHERE WITHIN THE CODY COVERDELL LIMITED SUPPLY CHAINS.

UPON REASONABLE REQUEST, OUR MAISON’S CONTRACTORS AND SUPPLIERS MUST IMPROVE AND CORRECT ANY DEFICIENCY DISCOVERED DURING ANY SUCH AUDITS. CODY COVERDELL LIMITED SHALL USE ITS REASONABLE ENDEAVORS TO ENSURE THAT ANY AND ALL CODY COVERDELL LIMITED SUPPLIER AND CONTRACTOR TEMPLATE CONTRACTS CONTAIN CLAUSES REQUIRING OUR MAISON’S CONTRACTORS AND SUPPLIERS TO ADOPT SIMILAR ANTI-MODERN SLAVERY STANDARDS AND PRACTICES.

CODY COVERDELL LIMITED IS COMMITTED TO MAKING THE WEBSITE ACCESSIBLE TO ALL PEOPLE, INCLUDING INDIVIDUALS WITH DISABILITIES. OUR MAISON HAS CONSTANTLY BEEN IN THE PROCESS OF MAKING SURE THAT THE WEBSITE, WWW.CODYCOVERDELL.COM, COMPLIES WITH THE BEST PRACTICES AND STANDARDS AS DEFINED BY SECTION 508 OF THE U.S. REHABILITATION ACT AND LEVEL AA OF THE WORLD WIDE WEB CONSORTIUM (W3C) WEB CONTENT ACCESSIBILITY GUIDELINES 2.0. THESE GUIDELINES EXPLAIN HOW TO MAKE WEB CONTENT MORE ACCESSIBLE FOR THOSE WITH DISABILITIES.