DISCLOSURE UNDER THE CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

e.l.f. Cosmetics is committed to conducting business in a legal, ethical, and responsible manner. We are opposed to human trafficking, forced labor, child labor, harassment and abuse, and other violations of human rights at any level, and we are committed to ensuring that the manufacturers and suppliers we work with meet our standards.

The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers to disclose its efforts to eradicate slavery and human trafficking from its supply chain. Below are our required disclosures under this act:

  1. We require our suppliers to agree in writing to, and adhere to, our Supplier Policy Statement. Our Supplier Policy Statement addresses working conditions for suppliers and specifically prohibits, among other things, the use of involuntary or forced labor, human trafficking, child labor, human rights violations, animal testing, and harassment and abuse.

  2. We do not at this time engage in audits of our suppliers specifically regarding violations of human trafficking and slavery. However, if we suspect a supplier is in violation of our Supplier Policy Statement, we will conduct an inquiry. If a potential violation is identified, we will promptly address the issue with the supplier and set expectations for how the situation is to be addressed. If a non-compliance issue is not resolved in a timely manner, then we will re-evaluate our business relationship with that supplier, up to and including termination of the business relationship.

  3. As noted above, our Supplier Policy Statement requires our suppliers to comply with local laws, prohibits slavery and human trafficking, and states that our suppliers have made a commitment to basic principles of human rights. However, our Supplier Policy Statement does not at this time require our suppliers to specifically certify that materials incorporated into our products comply with the laws regarding human trafficking and slavery of the country or countries in which the suppliers are doing business.

  4. We maintain internal accountability standards and procedures for contractors and suppliers failing to meet company standards regarding human trafficking and slavery.

  5. We do not at this time provide company employees and management with specific formal training on human trafficking and slavery.