Introduction

PMI WW Brands, LLC and its affiliated entities, including the Stanley 1913 brand, are committed to maintaining responsible business practices throughout global operations and supply networks. This Responsible Supply Chain Statement describes the company’s approach to identifying, preventing, and addressing risks related to human rights, ethical labor practices, forced labor, human trafficking, and child labor. The statement is prepared in accordance with applicable supply chain transparency requirements, including the California Transparency in Supply Chains Act, the United Kingdom Modern Slavery Act, and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Business Commitment and Values

Stanley 1913 operates with a commitment to creating workplaces and supplier relationships based on respect, fairness, safety, and inclusion. The company’s expectations regarding ethical conduct are established through its internal business policies and Supplier Code of Conduct. These standards apply throughout the company’s operations and extend to third-party manufacturing partners responsible for producing Stanley 1913 products.

The company’s direct activities primarily include corporate management, product development, design, and sales operations. Products are manufactured through approved external suppliers, and Stanley 1913 works closely with these partners to encourage responsible practices, compliance with applicable laws, and continuous improvement throughout the supply chain.

Policies and Ethical Standards

Stanley 1913’s responsible sourcing framework is based on internationally recognized human and labor rights principles, including standards established by the International Labour Organization. The Supplier Code of Conduct outlines the minimum requirements expected from suppliers, covering areas such as prohibition of forced labor and child labor, prevention of harassment and abuse, fair compensation, reasonable working hours, workplace health and safety, freedom of association, non-discrimination, and environmental responsibility.

The company regularly reviews and updates its policies to reflect evolving global standards, industry expectations, and emerging human rights considerations. Employees are also required to follow ethical business principles that address responsible decision-making, supplier relationships, legal compliance, and integrity in business operations.

Supply Chain Risk Management

Stanley 1913 recognizes that responsible supply chain management requires ongoing evaluation and cooperation with suppliers. Before establishing relationships with new manufacturing partners, the company conducts assessments to understand potential social and human rights risks associated with suppliers, production categories, and sourcing locations.

Risk evaluations may consider geographic conditions, industry-specific challenges, supplier performance history, and information from recognized external resources. The company also performs continuing reviews of supply chain conditions and updates sourcing strategies when necessary.

Supplier Approval and Monitoring

New suppliers must complete qualification procedures before beginning production. These procedures may include social compliance assessments, audits, and reviews of workplace practices. Suppliers are required to meet minimum compliance expectations and establish improvement plans when additional progress is needed.

Approved suppliers enter contractual agreements requiring compliance with the Supplier Code of Conduct and applicable laws. These commitments extend to suppliers’ own operations as well as relevant subcontractors and business partners.

Stanley 1913 monitors supplier performance through internal reviews and independent third-party assessments. Audits may include announced, partially announced, or unannounced facility inspections designed to evaluate compliance with labor standards, workplace safety requirements, and ethical business expectations.

The company has expanded its social responsibility monitoring efforts beyond direct manufacturing partners by increasing engagement with additional supply chain levels. Through collaboration with primary suppliers, Stanley 1913 works to improve transparency, provide training, and strengthen responsible sourcing practices.

Corrective Actions and Accountability

When potential violations are identified, Stanley 1913 investigates concerns and works with suppliers to develop corrective action plans. Suppliers are expected to address identified issues promptly and implement measures to prevent recurrence.

Human trafficking, forced labor, modern slavery, and child labor are treated as serious violations requiring immediate attention and appropriate remediation. Depending on the circumstances, Stanley 1913 may require additional oversight, suspend business activities, or end supplier relationships when acceptable corrective actions cannot be achieved.

Training and Continuous Improvement

Stanley 1913 provides regular training for employees and suppliers to strengthen understanding of ethical standards and responsible labor practices. Supplier education may include guidance on workplace safety, responsible recruitment, labor requirements, and compliance expectations.

Suppliers are responsible for ensuring that workers and contractors receive appropriate training regarding the Supplier Code of Conduct. They must also maintain labor compliance programs based on recognized international standards, including procedures for identifying risks, providing corrective actions, and improving future performance.

In addition to compliance training, Stanley 1913 supports practical improvements at manufacturing facilities, including safety preparation, emergency response activities, fire prevention measures, and workplace health initiatives.

Effectiveness Review

Stanley 1913 evaluates the effectiveness of its supply chain responsibility programs through audits, supplier reviews, grievance reporting systems, and ongoing assessments. Performance information is regularly reviewed to identify areas requiring improvement and to strengthen future actions.

The company continues to refine its policies, procedures, and supplier engagement methods based on audit findings, industry developments, and changing expectations related to responsible business conduct.

Contact Information

For questions or requests related to responsible supply chain practices, please contact:

Email: stanley1913@gmail.com

Telephone: 1-800-692-8541

Attestation

I confirm that I have reviewed the information contained in this Responsible Supply Chain Statement for PMI WW Brands, LLC. Based on reasonable diligence and available information, I affirm that the contents of this statement are accurate and complete in all material respects for the purposes of applicable supply chain transparency requirements.

Full Name: Matt Navarro

Title: Global President, PMI WW Brands, LLC.

Date: June 5, 2026