CA Transparency Disclosure

In compliance with California’s Transparency in Supply Chains Act of 2010, U.S. Vision and its affiliates make the following disclosure.

VERIFICATION

U.S. Vision, operating as JC Penney Optical, is committed to fair labor practices within our supply chain. We therefore engage in verification of our product supply chains through the use of reputable manufacturing suppliers who comply with the Act. In addition, U.S. Vision and its affiliates require that letters of compliance, that are signed by authorized officers of the manufacturing company, be submitted to them semi-annually. When partnering with any new suppliers an initial compliance letter is required before any purchase orders are submitted. At this time U.S. Vision does not engage in any third party verification but will continue to evaluate this process to see if it becomes necessary.

AUDIT

U.S. Vision, operating as JC Penney Optical, does not currently conduct on-site announced or unannounced audits of suppliers to evaluate supplier compliance with company standards for slavery and human trafficking in supply chains but will continue to evaluate this process to see if it becomes necessary.

CERTIFICATION

U.S. Vision, operating as JC Penney Optical, requires its direct suppliers to certify their compliance with all applicable laws, rules, regulations, orders, conventions, ordinances and standards that relate to anti-slavery and human trafficking in the country or countries that they do business in all aspects that relate to the manufacture and supply of products and services purchased. A letter confirming this compliance will be required from each supplier on a semi-annual basis. All suppliers are aware that they must stay in compliance to continue to do business with U.S. Vision or any of its affiliates.

INTERNAL ACCOUNTABILITY

U.S. Vision, operating as JC Penney Optical, should be made aware of any violation of our company standards regarding slavery and human trafficking by an employee or supplier in the manufacture or supply of products and services purchased. U.S. Vision will investigate any suspected case of non-compliance. If a non-compliant company is uncovered we will provide written notice and a specified period of time to take corrective action. A non-compliant supplier that can not, or will not meet the requirements to become compliant within the time period provided will have their business relationship terminated. Any employee found to be non-compliant will face corrective action or termination.

TRAINING

U.S. Vision, operating as JC Penney Optical, provides company employees and management, who have direct responsibility for their supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. Our supply chain management staff consists of two vice presidents, one director, three supervisors and two buyers. Every member receives training on all company policies, practices and procedures designed to ensure that out supply chain is free of any type of coerced labor, including how to spot warning signs of potential human rights violations. In addition, periodic reviews of laws and regulations governing importation into the United States are conducted. A California Transparency in Supply Chains Act Training Manual is provided twice a year during a semi-annual training session.

We encourage employees, business partners and the public to communicate to us any concerns, questions, or issues they may have. Please direct such communication to our Supply Chain Ethics Department, at U.S. Vision, 5 Harmon Drive, Glendora, NJ 08029.