LL Flooring is committed to being a positive force in the communities in which it and its suppliers operate. To that end, we support the eradication of child labor, the elimination of human trafficking and the adherence to applicable laws governing the employment of workers. We believe that implementing high standards for worker health and safety leads to higher-quality products and reduced costs we can pass on to our customers.  The following disclosure, which is provided pursuant to California Transparency in Supply Chains Act of 2010, Civil Code Section 1714.43, outlines our efforts in this area.


CERTIFICATION:  By doing business with us, all of our suppliers are required to agree to our "Standards for Vendor Partner Conduct," which includes a Supply Chain, Environmental and Labor requirements. This policy expressly prohibits our suppliers from using child labor and forced labor.  More generally, these policies require our suppliers to comply with all applicable labor and employment laws, rules, regulations, including laws relating to forced labor. Additionally, the standard terms and conditions of our purchase orders similarly require our suppliers to represent and warrant that they comply with applicable laws and regulations. We have the contractual right to cancel any purchase orders and cease doing business with any supplier that fails to adhere to these mandatory provisions.


VERIFICATION AND SUPPLIER AUDITS: We work with a select group of vendors and factories with whom we have cultivated long-standing relationships. We often pay announced and unannounced visits to our suppliers' factories and assess their adherence to our code of conduct and its protocols concerning labor as well as health and safety matters. For potential new vendors, we will often visit their facilities to assess their ability to comply with our environmental and social policies prior to ordering products from them. Additionally, we utilize third party auditors as part of our process for reviewing risk based supply chains and evaluating and addressing risks relating to supplier compliance with our labor and employment practice standards.

In the event we learn that any supplier has engaged in behavior that has violated our policies, we take appropriate remedial action, which may include termination of the relationship and/or reporting to the relevant authorities.


INTERNAL ACCOUNTABILITY: Each of our employees is required to abide by LL Flooring Code of Business Conduct and Ethics (a copy of which is available on our Investor Relations webpage) and comply with applicable law, including labor and employment laws. We exercise an open-door policy for employees to report any issues to their supervisors or human resources department. We also maintain a whistleblower hotline via both telephone and internet which permits employees to anonymously report any issues or concerns that they may have. The hotline information is posted in all of our locations as well as on our intranet.  If we become aware that any of our employees are failing to follow these standards or otherwise is helping facilitate slavery in our supply chain, we will take appropriate action, which may include training, increased auditing, disciplinary action, and termination.


TRAINING:  We emphasize our commitment to labor requirements with our personnel. We train our employees who are involved in our supply chain about our environmental and social responsibility policies and the identification and mitigation of risk.