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TORRID LLC VENDOR CODE OF CONDUCT

Workplace Code of Conduct
Torrid LLC has formulated the following set of standards defining decent and humane working conditions, and has created the attached Principles of Monitoring Workplace Obligations of Companies for use in adherence to those standards. Torrid LLC wishes to support the ideals explained below through maintaining this Workplace Code of Conduct and the attached Principles, and choosing not to do business with Vendors or other organizations that do not act in accordance with these rules and guidelines.

Torrid LLC believes that consumers should have confidence that products that are manufactured in compliance with these standards are not produced under exploitative or inhumane conditions. Consequently, Torrid LLC asks each of its Vendors to comply with the requirements of this Code of Conduct as to it and its employees, and to ensure, monitor and maintain compliance with this Code of Conduct (through implementation of procedures in accordance with the attached Principles) by it and by each person, company or otherorganization, both domestic and international, that the Vendor works with in connection with its business relationship with Torrid LLC

General
In general, each Vendor (and those with whom the Vendor conducts relevant business) shall comply with all applicable laws relating to workplace safety, conduct and other subjects addressed by this Code of Conduct.

For purposes of this Code of Conduct and the attached Principles, all references to “law” or “laws” mean all applicable Federal, state, region, local or other jurisdictional laws, rules and regulations, including those by a government-authorized agency, applicable from time to time to the particular place or practice referenced.

This Code of Conduct and implementation of procedures in accordance with the attached Principles are intended to augment, not replace, applicable laws. To that end, Torrid LLC requires compliance with both applicable laws and the Workplace Code of Conduct (in accordance with the attached Principles), and such compliance shall obligate adherence to the higher, or more “worker-friendly,” standard in cases of conflict, omission, or inconsistency.

Minimum Requirements

Forced Labor. There shall not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise.

Child Labor. No person shall be employed at an age younger than 15 years; provided that this minimum age may be 14 where permitted
by law.

Harassment or Abuse. Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment or abuse.

Nondiscrimination. No person shall be subject to any discrimination in employment, including with respect to hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.

Health and Safety. Employers shall provide a safe and healthy working environment designed to maximize prevention of accidents and injury arising out of, linked with, or occurring in the course of work or as a result of the operation of employer facilities.

Freedom of Association and Collective Bargaining. Employers shall recognize and respect all applicable laws regarding freedom of association and collective bargaining.

Subcontracting and Homeworkers. Vendors and manufacturers may not use subcontractors for the manufacture of Torrid LLC merchandise or components without the express written consent of Torrid LLC, and only after the subcontractor has entered into a written commitment with Torrid LLC to comply with this Code of Conduct. Vendors and manufacturers may not contract, use or employ homeworkers in the production of merchandise or components for Torrid LLC

Wages and Benefits. Employers must demonstrate recognition that sufficient wages are essential to meeting their employees' basic needs. Accordingly, employers shall pay employees at least the minimum wage required by local law and shall provide all legally mandated benefits.

Hours of Work. Except in extraordinary business circumstances, employees shall not (1) be required to work more than the lesser of (a) 60 hours per week (of which at least 12 hours must be paid at the applicable premium overtime rate for the jurisdiction for the initial period beyond the relevant defined workday), or (b) the weekly limit on regular and overtime hours allowed by the law of the relevant jurisdiction or, where the laws of such jurisdiction do not so limit the hours of work, the regular work week in such jurisdiction plus 12 hours overtime (at the rate described above); or (2) be entitled to less than one full day off in every seven day period.

Overtime Compensation. In addition to compensation for regular hours of work, employees shall be compensated for overtime hours at such premium rate or rates as are legally required in the jurisdiction or, in those jurisdictions where no such laws apply, at a rate at least equal to their regular hourly compensation rate.

Protection of the Environment. Vendors and manufacturers must comply with all applicable environmental laws and regulations.

Monitoring and Compliance. Manufacturers will authorize Torrid LLC and its designated agents (including third parties) to engage in monitoring activities to confirm compliance with this Code of Conduct, including unannounced on-site inspections of manufacturing facilities and employer-provided housing; reviews of books and records relating to employment matters; and private interviews with employees. Manufacturers will maintain on site all documentation that may be needed to demonstrate compliance with this Code of Conduct.