Supplier Responsibility

Disclosure Statement Pursuant to California Transparency in Supply chains Act of 2010

Robert Wayne Footwear is a divison of L&M Footwear, Inc. L&M Footwear is committed to the highest standards of social responsibility. As part of this commitment we are obligated to ensure our products are produced in an ethical and legal manner. L&M Footwear takes seriously the federal and international efforts to end human trafficking and slavery.

Supply Chain Verification

L&M Footwear’s policy is to evaluate potential contracted factories before they enter the supply chain to assess compliance with standards including country-related risk for issues including human trafficking and slavery. We source our products and materials from suppliers that we believe to be both reputable and compliant with applicable laws and their own internal standards and policies prohibiting slavery and human trafficking. Although we currently do not have formal policies or procedures of our own in place, we believe that the company employees responsible for managing our supply chain have sufficient knowledge and experience to evaluate and asses the risks posed by each supplier, and to detect potential warning signs that a supplier may be failing to adhere to the proper standards or to monitor and ensure compliance by its own supply sources.

Supply Chain Certification

L&M Footwear does not currently have a formal supplier compliance verification program in place. However, we remain committed to evaluating and revising our practices, and are working on developing standards for supplier certification including the creation of a Supplier’s Code of Conduct that will expand in detail our expectations of our suppliers regarding human rights, and establishment of standards and procedures for suppliers that fail to meet our company requirements regarding forced labor and trafficking.

Training and Internal Accountability

In light of the knowledge and experience of our existing supply chain partners, we have not instituted formal employee training programs, nor have we utilized the services of outside third parties to audit or verify supplier compliance. Those employees and management with direct responsibility for supply chain management and audits are provided information on L&M Footwear’s policies with regard to forced labor, including human trafficking and slavery. These employees and management cooperate with suppliers to correct any breaches of employment, health, safety and environmental precedent and practices, and specifically for any type of forced labor. If employees of L&M Footwear who are responsible for direct responsibility of supply chain management fail to fulfil their duties, they may be subject to discipline.

BN 18628254v1

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