California Supply Chains Act

Venus Fashion, Inc., Lascana Fashion, Inc., and Creation, L Inc. (collectively herein, VENUS) take responsibility for ensuring our business operations support our social environmental standards. In the current global market, VENUS and our vendors must prioritize the ethical treatment and protection of the rights of individuals employed or engaged in our supply chain.

As part of the Otto Group, our parent company, we have adopted the amfori BSCI Code of Conduct for ourselves, our suppliers and agents (collectively herein, “Business Partners”), regarding the manufacturing of products for VENUS. The Otto Group, a founding member of the Business Social Compliance Initiatives (BSCI), has implemented significant initiatives to prevent human trafficking and slavery, which Venus strictly adheres to and to which it expects its Business Partners to also adhere. The amfori BSCI Code of Conduct establishes principles that focus on labor protection and improving the working conditions in the supply chain that specifically addresses human trafficking and slavery, stating in part:

No Bonded Labour: Business partners shall not engage in any form of servitude, forced, bonded, indentured, trafficked or nonvoluntary labour.1

Current Activities:

VENUS has focused on implementing concrete steps to assist in upholding our compliance with the amfori BSCI Code of Conduct and to prevent human trafficking and slavery from our supply chain, including:

Certification: Venus requires its Business Partners to provide written confirmation that they have thoroughly reviewed and will comply with the provisions outlined in the amfori BSCI Code of Conduct.

Verification: VENUS collaborates with the Otto Group and third-party auditors to observe and audit our supply chain program across all countries. This includes administering validation measures to identify, evaluate, and lessen the risks associated with human trafficking. An integral part of this process is every Business Partner is required to provide written disclosure to VENUS, specifying the production sites utilized directly or indirectly in the manufacturing of goods or services for VENUS.

Audits: On a regular basis, VENUS requests Business Partners to submit social audits for each of its production sites and its suppliers to ensure compliance with the amfori BSCI Code of Conduct. These audits and assessments can be performed by authorized amfori BSCI auditors or authorized third-party auditors, with semi-announced notifications. In cases where non-compliance is detected, VENUS mandates prompt corrective measures. Should a Business Partner prove unable or unwilling to comply, or if there are instances of recurring or significant non-compliance, VENUS retains the right to terminate its relationship with any Business Partner or insist on implementing necessary corrective actions.

Training: VENUS regularly provides training to its sourcing team on our ethical and social responsibility standards. Additionally, training on ethical and social responsibility standards is available to Business Partners through amfori BSCI.

Internal Accountability: VENUS requires immediate reporting from its Business Partners regarding any violation of the amfori BSCI Code of Conduct. We diligently investigate all reports we receive, and we strictly prohibit any form of retaliation or disciplinary actions against individuals or entities, whether initiated by VENUS employees or Business Partners, for raising concerns or making reports about compliance.

1amfori BSCI, amfori BSCI Code of Conduct,