AVEDA, a subsidiary of Estée Lauder Companies SUBJECT Ethical Sourcing Policy APPROVAL POLICIES AND PROCEDURES EFFECTIVE DATE PAGE 1 OF 1 POLICY STATEMENT: Aveda places value on the social and environmental benefits brought about by responsible sourcing practices. Thus, Aveda follows sourcing guidelines that ensure a safe and healthy workplace for the people who produce its goods and that respect environmental and social values. In furtherance of this policy, Aveda gives priority to suppliers whose practices meet or exceed Aveda’s own Ethical Sourcing Standards of Excellence. DEFINITION: Sourcing refers to the process of procuring raw materials, packaging and accessories. Supplier practice refers to the manner in which our suppliers conduct their business, including, but not limited to, operations, production and processing systems, and workplace conditions. Aveda’s Sustainable Agriculture Sourcing Policy (pending) provides additional guidance and requirements for sourcing raw materials. PURPOSE: The purpose of this policy is to ensure that products and materials purchased by or on behalf of Aveda are aligned with Aveda’s mission and that Aveda identifies, develops and promotes social and environmental responsibility at all levels of its supply chain. SCOPE: This policy applies to suppliers of primary packaging and accessories. The scope of this policy will progressively expand to cover the totality of our business. PROCEDURE: Please refer to Aveda’s Ethical Sourcing Standards of Excellence following this policy which provide the framework for implementing this policy. Aveda will work with suppliers to gauge compliance with and improve practices according to the Ethical Sourcing Standards of Excellence. Affected department heads will report annually on their departments’ performance against this Ethical Sourcing Policy to the management team. EXCEPTION Aveda reserves the right to modify this policy at any time without prior written notice. Ethical Sourcing Standards of Excellence ENVIRONMENTAL LEADERSHIP AND RESPONSIBILITY Does the company have a published policy, vision statement or charter committing them to protect the environment? Does the company demonstrate environmental leadership and responsibility? Does the company have a staff position responsible for overseeing environmental issues? Does the company use "design for the environment" principles when developing new products or constructing new facilities? Does the company have a program for recycling materials used at their facility? Does the company have a policy against using wood and paper products derived from the harvesting of old-growth forests? Does the company give preference to sustainably managed forest products? Does the company measure and attempt to reduce resource consumption? SOCIAL RESPONSIBILITY AND LEADERSHIP Does the company have a social accountability statement, policy or code of ethics? Does the company monitor corporate social responsibility (CSR) performance? Does the company have a staff position responsible for overseeing social responsibility issues? Does the company have a system in place for supply chain social accountability? Does the company model socially responsible employer practices? Does the company ensure conditions of employment are fair and just?