Nine West, LLC. (the “Company” or “we”) is committed to legal compliance and ethical business practices in all of our operations worldwide. We choose suppliers and contractors who we believe share that commitment.

The Company conducts audits of its direct suppliers to evaluate compliance with the Company’s Standards for Contractors and Suppliers, which include standards for slavery and human trafficking in the supply chain. To determine factory selection and timing for audits we look at several criteria, including factory location (country), size, workforce composition and past compliance performance, if available, to determine facility risk and audit priority.

SUPPLIER CERTIFICATION.

The Company requires that all of its suppliers comply with applicable laws within their country of business regarding slavery and human trafficking. Since 1996, the Company has required all of its contractors and suppliers to adhere to its Standards for
Contractors and Suppliers, which, among other things, prohibits child labor and any form of forced, compulsory, bonded, indentured or prison labor and requires compliance with applicable laws and regulations regarding health and safety in working conditions.

TRAINING

The Company conducts internal training of its managers and employees with direct responsibility for supply chain management that specifically raises awareness of slavery and human trafficking and focuses on mitigating the risks within our supply chain. In addition, the Company’s internal corporate compliance employees, as well as third party monitors contracted to audit facilities in the Company’s supply chain, have participated in training jointly developed and delivered by the United Nations Global Initiative to Fight Human Trafficking (“UN.GIFT”) and the International Labor Organization (“ILO”).

That training helps internal and external monitors to thoroughly monitor the risk of forced labor in the Company’s supply chain and to develop and deliver training programs for agents, vendors and other supply chain partners on the issue, including how to identify and mitigate forced labor and trafficking risks in their recruitment processes.