SUPPLY CHAIN TRANSPARENCY

TWEEN BRANDS STATEMENT ON SUPPLY CHAIN TRANSPARENCY

Tween Brands strives to ensure that its products are produced in a socially responsible manner and to prevent complicity in abusive employment practices such as human trafficking and slavery.

To further these objectives, all our product vendors are bound by contract to abide by all applicable employment and human rights laws, as well as our Code of Conduct, which, among other things, emphasizes the importance of well-treated, fairly compensated workers. In addition, we have a monitoring and compliance program ("Monitoring Program"), which seeks to promote the maintenance of quality and safety standards in our manufacturing facilities and compliance with our Code of Conduct.

In order to maximize the effectiveness of our programs, we have internally verified our supply chain to identify areas of potential risk and then focused our resources, including our Monitoring Program, on certain vendors/factories, some which may be considered "high risk" as a result of being in particular industries and/or countries of origin. The majority of our current vendors/factories are required to participate in the Monitoring Program, and we continue to expand the program as time goes on.

Our Monitoring Program includes the following elements, among others:

Vendor/Factory Certification Agreements

Vendors/factories must (1) acknowledge in writing their agreement to comply with Tween Brands' Code of Conduct, and (2) provide written certification of their compliance with the Code of Conduct and all applicable employment and human rights laws. This written documentation is required at the time we require them to enter the Monitoring Program, which for most new vendors/factories means prior to the placement of any order with them.

Verification of Supply Chain and Audits of Suppliers

As indicated above, we verify your supply chain internally, not through a third party. Once a vendor/factory is part of our Monitoring Program, we require audits of product manufacturing facilities to determine whether the facility is in compliance with applicable laws and Tween Brands' standards. Audits may be conducted through independent third-party audits of vendor facilities, which can include unannounced audits.

Accountability/Vendor Non-Compliance

Vendors/factories that are found to violate Tween Brands' Code of Conduct or other applicable laws and standards are held accountable for those violations through corrective action plans and other disciplinary measures, up to and including termination of the business relationship.

Training

We provide internal training on our Monitoring Program, including our Code of Conduct and other company standards, to ensure the necessary participants in supply chain management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including slavery and human trafficking, with a particular focus on mitigating risk.