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Disclosure Required Under the California Transparency in Supply Chains Act



On January 1, 2012, the California Transparency in Supply Chains Act of 2010 went into effect in the State of California. Under the law, certain large manufacturers and retailers are required to disclose their efforts to eradicate slavery and human trafficking within their supply chains. The law’s underlying purpose is to educate consumers, so that consumers can make informed decisions and purchase goods from companies that consumers believe responsibly manage their supply chains.

Suppliers

Empire is committed to purchasing flooring and window products from suppliers that strive to treat all employees fairly and maintain excellent labor practices. Empire enters into vendor agreements with its direct suppliers. Such agreements require Empire’s suppliers to comply with all applicable laws and regulations, which would necessarily prohibit the use of forced or child labor, slavery, and human trafficking. While Empire does not regularly audit or verify its suppliers, or require “certifications” from its suppliers regarding their compliance with the laws regarding slavery and human trafficking, Empire continuously evaluates its suppliers, including the quality of their products and their adherence to their vendor agreements. Empire holds its suppliers accountable for compliance with its vendor agreements. Any Empire supplier that fails to comply with applicable laws or ethical business practices may be subject to immediate business suspension or termination of the agreement upon notice by Empire.

Employees

All of Empire’s employees are expected to conduct business ethically and in accordance with all applicable laws and regulations. Empire further requires that all of its employees comply with Empire’s Code of Conduct and Company Policy Manual, which incorporates Empire’s company policies, procedures and the obligation to comply with applicable laws and regulations. Empire’s employees are required to acknowledge the Code of Conduct and Company Policy Manual at the outset of their employment and continuing thereafter. Failure to act in accordance with those policies may result in corrective action or potential termination of employment. Empire also continuously develops and enhances its training programs for its employees, and certain of its employees and management involved in the supply chain also have received specific training and education relative to the Act.

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