SUPPLY CHAIN DISCLOSURE

Naroz LTD is committed to holding itself and its suppliers to the highest legal and ethical standards. This commitment includes our dedication to ethical and fair working conditions throughout our supply chain.

In North America, we report on our efforts to eradicate forced and child labor and human trafficking as required under the following legislation:

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 (“CALIFORNIA ACT”) CANADA FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT (“CANADA ACT”)

OUR BUSINESS

We are a global luxury brand with a clear philosophy: to design beautiful, timeless products across handbags, footwear, apparel, jewelry, home and a range of accessories. Empowering women is our guiding principle, underpinning Naroz design philosophy and driving the work of the Naroz LTD Foundation.

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Naroz LTD takes steps to prevent and reduce the risk of forced and child labor in its activities and supply chains as outlined below. We report on these activities under relevant legislation in California, Canada, and in the United Kingdom.

More information about our philosophy, approach, and impact is available here.

STRUCTURE, ACTIVITIES AND SUPPLY CHAINS

Naroz LTD operates, sources, and manufactures goods globally: we partner with responsible suppliers that are capable of meeting our high product and production standards, Naroz reporting entity in Canada, imports into and sells goods in Canada.

POLICIES, DUE DILIGENCE PROCESSES, AND ACCOUNTABILITY

Our Vendor Code of Conduct sets forth our standards for legal and ethical conduct in the supply chain, and is based on internationally accepted principles, including the International Labor Organization’s Declaration on the Fundamental Principles and Rights at Work. All suppliers are required to comply with our Vendor Code of Conduct, which addresses discrimination and harassment, women’s rights, working hours, wages and benefits, health and safety, freedom of association and collective bargaining, and environmental protection, in addition to forced and child labor.

We encourage our employees and our suppliers to raise concerns about violations of our Code of Conduct, other policies, or any law. We provide an ethics hotline to our employees that is maintained by independent third-party operators through which concerns may be raised anonymously and we encourage suppliers to report their concerns.

We investigate all concerns that are raised and prohibit any form of retaliation against anyone who has put forward a concern in good faith.

SUPPLY CHAIN VERIFICATION

Before engaging in business with a new supplier or subcontractor, we conduct an initial screening to assess potential risk, including potential risk for forced and child labor. If such risk is identified, we would not approve work with that supplier. We engage a third-party to support our due diligence efforts, both at the outset of the relationship and on an on-going basis.

SUPPLIER CERTIFICATIONS

All Naroz LTD suppliers and subcontractors are required to acknowledge and certify compliance with our Vendor Code of Conduct. Additionally, we collect documentation from different tiers of select supply chains attesting to the specific production processes at each facility and to the origin of raw materials used in production.

REMEDIATION MEASURES

Naroz LTD has not identified any forced or child labor in our activities or supply chains. Measures to remediate any such activity or any loss of income resulting from eradication of forced or child labor have therefore been unnecessary.

TRAINING

All Naroz LTD employees undergo annual training on the Naroz LTD Code of Conduct. We also train suppliers on our Vendor Code of Conduct, which includes forced labor updates, and the Naroz LTD sourcing teams are trained on risks within and traceability of the supply chain.

ASSESSING EFFECTIVENESS

We continue to review the effectiveness of the measures we have taken to ensure there is no forced labor or child labor in our supply chains. We will continue to keep our procedures under review.

CANADA ACT APPROVAL AND ATTESTATION

This Report is made pursuant to the Bill S-211, Fighting Against Forced Labour and Child Labour in Supply Chains Act and is published on behalf of Naroz LTD  This Report describes activities undertaken during the financial year ending December 31, 2023.

This Report has been approved by the Board of Directors of Naroz LTD.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for Naroz LTD Canada ULC. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act for the reporting year listed above.