California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010 (”CTSCA”) requires companies above a certain size that manufacture or sell products in California to disclose their efforts (if any) to address the issues of human trafficking and slavery. The CTSCA allows consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Purple Innovation, LLC (”Purple") strives to achieve and maintain high standards of corporate integrity and ethical behavior. Purple and its employees adhere to the Purple Code of Ethics. Purple expects that its suppliers will adopt the relevant provisions of Purple’s Manufacturer Code of Conduct that prohibits human trafficking and slavery and otherwise conduct their businesses not only in a lawful manner but also in compliance with the same high standards of integrity and ethics. Purple expects that its suppliers will not support, promote, or engage in the practice of slavery or human trafficking, and it contractually requires suppliers to comply with the laws regarding anti-slavery and anti-human trafficking of the country or countries in which they are doing business. Purple suppliers are further expected to take reasonable and necessary steps to help ensure that their sub-contractors and sub-suppliers conduct business in compliance with the laws regarding anti-slavery and anti-human trafficking of the country or countries in which they are doing business. Suppliers are expected to promptly take corrective action to address any deficiencies identified with respect to compliance with the laws regarding anti-slavery and anti-human trafficking. If a supplier is found to be in violation of the laws regarding anti-slavery and anti-human trafficking, Purple reserves the contractual right to terminate its relationship with that supplier for failure to comply. Purple employees and management who have direct responsibility for supply chain management regularly visit and inspect its suppliers’ facilities to further ensure compliance with laws regarding anti-slavery and anti-human trafficking. Purple has zero tolerance for slavery, human trafficking, and child labor.

VERIFICATION:

Purple currently does not verify its suppliers in its supply chain to evaluate and address risks of slavery and human trafficking. Purple does not conduct third party verification of its suppliers’ compliance with anti-slavery and anti-human trafficking laws.

AUDITS:

Purple currently does not conduct independent and unannounced formal audits of its suppliers to evaluate compliance with Purple standards for anti-slavery and anti-human trafficking in its supply chain.

CERTIFICATIONS:

Purple does not require all its suppliers to provide any certifications regarding compliance with anti-slavery and anti-human trafficking laws of the country or countries in which they are doing business. However, Purple expects that its suppliers must not support, promote or engage in the practice of slavery or human trafficking, and it requires suppliers to comply with the laws regarding anti-slavery and anti-human trafficking of the country or countries in which they are doing business.

ACCOUNTABILITY:

Purple expects its employees, whose duties involve the Purple supply chain, to comply with all applicable laws and regulations relating to anti-human trafficking and anti-slavery. Purple takes the issues of slavery and human trafficking very seriously and will continue doing its part by responsibly managing its supply chains to eradicate human trafficking and slavery. All reports of alleged violations will be investigated by Purple. If an investigation indicates that corrective action is required, Purple will decide the appropriate steps to take, including discipline, dismissal, and possible legal proceedings. Disregard or deliberate ignorance of the law is not tolerated and may lead to disciplinary action.

TRAINING:

Purple requires periodic certification from our employees that they understand and will adhere to the Code of Ethics. Purple has conducted awareness training on anti-slavery and anti-human trafficking for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within its supply chain.