California Transparency In Supply Chains Act of 2010

Last updated April 2018

Destination XL Group, Inc., on behalf of itself and its subsidiaries ("DXLG"), is committed to providing its customers with top-quality merchandise that is manufactured responsibly. That means we expect workers making DXLG products to be treated fairly and with dignity and respect. In addition, we demand adherence to any and all appropriate international and U.S. laws, regulations and industry standards applicable anywhere DXLG operates. DXLG supports the intent of the California Transparency in Supply Chains Act of 2010 (the "Act").

DXLG sells both private-label and branded-label products. Our branded-label suppliers are provided with our Code of Conduct, Global Vendor Agreement and Vendor Compliance Guide (collectively the "DXLG Agreement") and they are informed that they are required to follow the DXLG Agreement. Since 2011, DXLG has incorporated the Act into its DXLG Agreement. We ask that you visit the websites of branded-label companies to read about their efforts in complying with the Act. Not all branded vendors have signed the VA.

The suppliers of our private-label products are held to DXLG's Agreement which addresses the concerns underlying the Act. Key elements of our practices regarding our private-label products are summarized below:

1. Verification

DXLG examines its product supply chain in an effort to uphold its commitment to work only with suppliers that strictly comply with the DXLG Agreement. Each year we require all of our direct suppliers to retain DXLG-approved, independent third-party auditors (the "Auditor") to examine relevant information about each supplier on our behalf. The Auditor evaluates the risks and vulnerability to slavery or human trafficking in the production of our supplier goods. Prior to DXLG conducting business with a new direct supplier, an initial audit is performed by the Auditor and the audit results are submitted to DXLG's Senior Director of Vendor Compliance & Quality Assurance for final review and approval

2. Audit

The DXLG Agreement asserts DXLG's right to terminate any supplier for cited violations including, but not limited to, slave labor, human trafficking or safety. In 2014, announced audits were conducted at all 30 private-label factories with which DXLG does business. The audits were conducted on site and consisted of the following components: facility tour, document review, confidential worker interviews, and an opening and closing meeting with the facility's key management. We require all suppliers to provide the Auditor with unrestricted access to the production facility and applicable records. After the audit, any violations of our DXLG Agreement are documented, and a detailed corrective action plan is required. Regular follow-up visits are also conducted to ensure efforts are made to correct any violations. DXLG severed ties with one supplier in 2014 due to its uncorrected unsatisfactory audit.

3. Certification

DXLG requires each private-label supplier to comply with our DXLG Agreement and Customs-Trade Partnership Against Terrorism (C-TPAT) standards to ensure the merchandise does not violate the laws regarding slavery and human trafficking of the country or countries in which it transacts business.

The following language is incorporated into DXLG's Global Vendor Agreement:

"The Merchandise is manufactured, assembled, imported, sold, shipped, packaged, labeled and marketed in accordance with all applicable international (in the countries in which the parties are doing business), U.S. federal, state and local laws, ordinances, executive orders and regulations and industry standards including, without limitation, laws, regulations, executive orders and standards applicable to wages, work hours, work place safety, protection of the environment, and the prohibition of discrimination based on the basis of race, color, national origin, gender, religion, disability, sexual orientation or political opinion. Vendor further represents and warrants that convict labor, child labor, forced labor and/or indentured labor under penal sanctions was not employed, in whole or in part, in any stage of the production, manufacture, assembly of the Merchandise or any material or component thereof."

4. Internal Accountability

DXLG's Sourcing Department and its Senior Director of Vendor Compliance & Quality Assurance have developed and maintain internal accountability which consists of candid communications with the auditors, vendors, suppliers and agent compliance teams. DXLG's private-label product factories' standards are monitored by the Auditors with direct reporting to DXLG. The Auditor provides DXLG with an Audit Findings Report (the "Audit Report") within five (5) business days of the completion of the audit. The Audit Report provides detailed information for DXLG to understand the context of any non-compliance findings, including the severity and frequency of the infraction. DXLG reviews each finding with the Auditor and approves the recommended corrective action steps and timeframe. DXLG asserts its right to terminate any supplier for cited violations including, but not limited to, slave labor, human trafficking or safety.

5. Training

DXLG's Senior Director of Vendor Compliance & Quality Assurance provides routine training on all DXLG Agreement requirements to DXLG's associates who work in sourcing and/or production and who visit suppliers as part of their job responsibilities. The associates are made aware of the indicators of slave labor and human trafficking, and are required to report any potential issues for further investigation. DXLG strives to keep the appropriate personnel knowledgeable about and attentive to, social compliance concerns such as human trafficking and slavery.

^c