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DISCLOSURE STATEMENT PURSUANT TO
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

Spencers supports the right of all individuals to be free from slavery in the workplace. Spencer's abhors the practice of human trafficking and slavery and applauds efforts being made globally to eliminate this practice. Spencer's requires all of its suppliers to be compliant with all local and national laws governing slavery and human trafficking in countries in which they do business. By accepting a purchase order or contract, every supplier certifies that it conducts business pursuant to local and national laws related to employment and its failure to do so will be considered a breach of the contract. While it does not conduct its own audit of suppliers to confirm compliance with slavery and human trafficking laws, Spencer's does require that all domestic suppliers certify compliance with all employment laws and that all international suppliers be verified by an independent, third-party auditor to confirm the suppliers' compliance with all employment laws. Additionally, Spencer's has adopted a policy for its employees and contractors that sets forth its expectations and standards with regard to the fair treatment of its employees. Spencer's policy specifically prohibits forced labor. Spencer's provides training on these standards for its employees and management.